New Silver Review 2026: What Sits Under the Income Fund's 12% Preferred Return
New Silver Lending, a West Hartford fix-and-flip lender, sells accredited investors one product: the New Silver Income Fund, which holds the junior, first-loss slice of a pool of New Silver's own loans. Sky (formerly MakerDAO) lends the senior slice at a 7% stability fee, and on a $100,000 loan at 9% with $80,000 borrowed at 7%, the fund's $20,000 slice earns 17% if the loan pays and is the first money lost if it does not. The fund markets a 12% preferred return paid monthly and reports 17.07%, 15.51% and 12.00% for 2023 to 2025 and a monthly return of 0.50% for September 2026. Qiro, an outside credit appraiser, says New Silver buys loans 60 days late out of the pool at par. The fund reported no annual audit on its January 2024 Form ADV, and its last Form D, in November 2023, reported $265,000 sold.
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What the data actually shows - TL;DR
New Silver Lending LLC, founded in 2018 by Kirill Bensonoff and Alex Shvayetsky, makes short-term loans to real estate investors who buy, renovate and resell houses. Its investor product, the New Silver Income Fund, LLC, does not lend directly: it holds the junior tranche of NS Pool LLC, New Silver's own special purpose vehicle, which buys New Silver's loans.
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The senior tranche is financed by Sky (formerly MakerDAO) through vault RWA002-A at a 7% stability fee, with a 20% minimum junior share. That 80/20 split is four dollars of senior debt per dollar of junior capital; Qiro's May 2026 appraisal put the actual split at $36.5 million senior and $12.7 million junior, about 2.9 to one. A worked example shows what the investor owns.
Take a $100,000 loan at 9% (New Silver's published fix-and-flip rates run from 9%) funded $80,000 by the senior lender at 7% and $20,000 by the junior tranche: the loan pays $9,000, the senior lender takes $5,600, and the junior slice keeps $3,400, 17% on its $20,000. If the loan defaults, the junior $20,000 absorbs the loss before the senior lender loses anything. 'Every loan is first-lien' describes the loans; the investor holds the slice that absorbs losses first.
New Silver reports returns of 17.07% (2023), 15.51% (2024) and 12.00% (2025) and a monthly return of 0.50% for September 2026, after Qiro had described the return as 'currently at the preferred return threshold'. No loan has been reported overdue; Qiro attributes that to New Silver buying loans 60 days past due out of the pool at par, while the memorandum says New Silver 'will seek to repurchase or replace non-performing loans', and neither the contractual obligation nor the volume of buybacks is public. The fund reported no annual audit on its January 2024 Form ADV and its current audit status is unconfirmed; its last Form D, filed November 2023, reported $265,000 sold to three investors; and the fund's materials do not mention the 2019 Massachusetts consent order against its chief executive.
The fund holds the junior tranche of NS Pool LLC; Sky's vault RWA002-A holds the senior DROP tokens at a 7% stability fee. The modeled structure is 80/20, four to one; Qiro (May 2026) reported $36.5 million senior (73.93%) and $12.7 million junior (26.07%), about 2.9 to one. Qiro's stress test: 'each 1% of portfolio default translates to a 5% impact on junior tranche capital', and the 12% preferred return is breached at about a 2% default rate with 50% loss severity.
Stated net returns: 17.07% (2023), 15.51% (2024), 12.00% (2025), then reported monthly returns of 1.00% January to August 2026 and 0.50% for September 2026. The monthly figures in the same table sum to 18.09% for 2023 and 15.90% for 2024, not the 17.07% and 15.51% in its annual column. Qiro put the portfolio yield at 8.82% against the 7.00% senior cost in May 2026 and called the junior return 'currently at the preferred return threshold'. The figures are New Silver's and were not independently verified.
Qiro, describing the fund for infiniFi: 'any loan reaching 60+ days past due is purchased by the operating entity at par', which it says has kept investor losses at zero. The fund's offering memorandum says New Silver 'will seek to repurchase or replace non-performing loans'. Whether the buyback is a contractual obligation, and how many loans have been bought out, is not public. Any such support is only as strong as New Silver Lending's balance sheet, which is not public.
The last Form D sales figure is $265,000 from three investors of $20 million offered, on the November 2023 amendment (a name change; the May 2022 notice, as DeFi Securitized Mortgage Fund LLC, reported the same). The January 2024 Form ADV gives gross assets of $1,592,896 and eight owners; Qiro gives equity of about $10.3 million at FY2025, with $11.53 million contributed that year. No notice after November 2023 reflects that growth.
Form ADV (January 29, 2024), Schedule D, reported that the fund's financial statements were not subject to an annual audit and named no administrator other than the adviser; no later Form ADV is on file, so current audit status is unconfirmed. The fund's materials name no auditor. Ankura Trust Company verifies loans and covenants at the pool level for the senior lender.
Form ADV Item 11: the Massachusetts Securities Division's action against Kirill Bensonoff and Caviar over an unregistered 2017 coin offering ended in a consent order on February 26, 2019 (cease and desist, rescission offered, disgorgement, $50,000 penalty), without admission. New Silver's 2020 disclosure to Centrifuge called Caviar a separate venture. The fund's site and materials do not mention it.
Returns, portfolio figures and the $100,000 examples are New Silver's. Capital-stack figures are Qiro's (May 2026). The Sky vault debt is read on chain; the Form D and Form ADV figures are as filed. The fund's operating agreement was not available.
Visual Summary
The fund's reported returns and the pool beneath them
Returns as New Silver reports them (not independently verified); capital stack from Qiro's May 2026 appraisal; vault debt read on chain at month-ends.
2023 stated net return
17.07% (monthly figures repeat in threes)
2024 stated net return
15.51% (monthly figures repeat in threes)
2025 stated net return
12.00% (monthly distributions from July)
January to August 2026
1.00% a month
September 2026
0.50% (reported monthly return)
Pool, May 2026 (Qiro)
Sky senior $36.5M (73.93%); junior $12.7M (26.07%); yield 8.82% vs 7.00% senior cost
Pool, August 2026 (New Silver)
$43.1M of loans, 74 loans, 56 borrowers, 0 overdue
Sky vault RWA002-A debt, month-ends 2026 (on chain)
May 36.35M, Jul 38.37M, Aug 27.11M, Sep 26.85M, Oct 15.59M DAI; 9.11M on Nov 9; 7.00% fee
Quick Verdict
Is this platform right for you?
New Silver's Income Fund turns short, first-lien fix-and-flip loans into a 12% target by putting investors in the junior tranche of a pool that Sky finances at 7%. That works while the spread holds and, by Qiro's account, New Silver keeps buying late loans out at par; Qiro's May 2026 appraisal put the return at the hurdle, and the reported September 2026 monthly return was 0.50%.
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Meanwhile Sky's senior vault has shrunk from 36.35 million DAI in May to 9.11 million on November 9. The formal record is thin for a fund of about $10 million: short offering terms, no audit reported on the January 2024 Form ADV, a last Form D figure of $265,000, a return table with two series that differ, and a 2019 consent order against the chief executive that the fund's materials omit. Investors should see the operating agreement, any audited statements and the current senior financing before committing.
Best for
- Accredited investors who understand tranche leverage and want monthly income from residential bridge loans
- Investors comparing lender-sponsored credit funds
Avoid if
- You read '100% first-lien' as a senior position
- You need audited statements or full offering documents before investing
- You need dependable liquidity beyond a 5% quarterly cap
Top strengths
- Short, first-lien loans with stated 71% loan-to-cost and 60% loan-to-after-repair-value
- Pool-level controls negotiated for Sky: Ankura as trustee and verification agent, FCI as servicer, defined eligibility covenants
- A senior lender with public governance records since 2021, and a public on-chain vault
- Monthly investor updates with portfolio metrics
Key limitations
- Investors hold the first-loss tranche behind a senior lender (80/20 modeled; about 2.9 to one in May 2026)
- Return at the 12% hurdle in May 2026; reported September 2026 monthly return 0.50%
- Zero-loss record attributed to par buyouts whose obligation and volume are not public
- No fund audit reported in January 2024 (current status unconfirmed); no independent administrator named
- Last Form D figure from 2023; two return series that differ
- 2019 Massachusetts consent order against the CEO not disclosed in the fund's materials
Compare Before Deciding
Where New Silver fits against alternatives
Use these hooks to pressure-test whether this is the right platform, or whether a nearby alternative matches the job better.
How this compares to Groundfloor
Groundfloor
Retail fix-and-flip loans sold note by note under Regulation A.
How this compares to Iron Bridge Mortgage Fund
Iron Bridge Mortgage Fund
An unlevered first-lien bridge-loan fund with a long public record.
How this compares to DLP Capital
DLP Capital
Lender funds with related-party loans and a stated preferred return.
26%
Junior share of the pool (May 2026)
The fund's first-loss tranche, $12.7 million behind Sky's $36.5 million senior position (Qiro).
0.50%
Reported monthly return, September 2026
After 1.00% a month January to August; the 12% preferred return is 1.00% a month.
$265,000
Last Form D sales figure (November 2023)
Qiro gives equity of about $10.3 million at FY2025.
9.1M DAI
Sky's senior vault, November 9, 2026
Read on chain; 36.35 million on May 31 and 15.59 million on October 31.
Quick Answers
What most investors want to know first
The highest-signal facts first: minimums, liquidity reality, K-1 timing, and whether distributions are actually part of the experience.
Liquidity
No market for the units.
K-1 Timing
Not stated.
Distributions
Monthly since July 2025, per New Silver.
Overview
Platform Overview
A concise read on what the platform is, how the structure works, and where the practical friction shows up for real investors.
New Silver Lending LLC (West Hartford, Connecticut) originates business-purpose loans to real estate investors: fix-and-flip loans up to 18 months (9.00% to 11.00%), ground-up construction loans (10.25% to 11.25%) and 30-year DSCR rental loans. Since 2021 it has financed a large part of that lending through NS Pool LLC, a Delaware subsidiary that buys its loans and issues two tranches through the Centrifuge protocol: senior DROP tokens held by Sky (formerly MakerDAO) vault RWA002-A, and junior tokens held by New Silver and its investors. The New Silver Income Fund, LLC, formed January 12, 2022 as DeFi Securitized Mortgage Fund LLC and renamed in 2023, is how accredited investors buy into the junior side: $50,000 minimum, Rule 506(c), Class B non-voting units, New Silver Lending as manager.
New Silver Capital, the investor brand, markets the fund on capital.newsilver.com; subscriptions run through a CashFlow Portal page. Fortress-managed funds separately agreed in November 2024 to buy New Silver loans under a forward flow agreement; they are a buyer of loans, not an investor in the fund.
It markets a 12% preferred return paid monthly; reported returns fell from 17.07% in 2023 to 12.00% in 2025, and the reported monthly return for September 2026 was 0.50%. The fund reported no annual audit on its January 2024 Form ADV, and its last Form D (November 2023) reported $265,000 sold.
Company and people
New Silver Lending LLC, West Hartford, CT, founded 2018. Kirill Bensonoff (co-founder, CEO) and Alex Shvayetsky (co-founder, Chief Risk Officer) own it (Form ADV Schedule A); Eric Wilson (Chief Growth Officer) runs investor relations.
Regulation
New Silver Lending is a Connecticut exempt reporting adviser (CRD 324981, since January 23, 2023), not SEC-registered; latest Form ADV filed January 29, 2024. The fund sells under Rule 506(c) to accredited investors (Form D file 021-446303).
Fund terms
$50,000 minimum; 12% preferred return paid monthly; 12% to 14% net target; 90/10 split above the preferred return, paid at year end; management fee 1.75% (under $150,000) to 0.75% ($1 million and over); quarterly redemptions with 60-day notice, 90-day payout and a 5% of NAV cap; Schedule K-1.
Structure
Fund (Class B non-voting units) holds the junior tranche of NS Pool LLC, New Silver's loan-holding subsidiary; senior DROP tokens held by Sky vault RWA002-A at a 7% stability fee; Ankura Trust Company indenture trustee and verification agent; FCI Lender Services servicer.
Reporting
Monthly investor updates with portfolio metrics (August 2026: $43.1 million, 74 loans, 56 borrowers, 0 overdue). No annual audit reported on the January 2024 Form ADV; current status unconfirmed; no independent administrator named.
Court and enforcement record
Massachusetts consent order against Kirill Bensonoff and Caviar (2019, unregistered coin offering; disclosed on Form ADV). No action naming New Silver Lending or the fund located; New Silver appears as a lender in five federal bankruptcy or foreclosure-related dockets.
ASWhat the documents and the chain show
- Investors hold the first-loss tranche: 80/20 modeled, about 2.9 to one in May 2026, about 63% senior-funded on August 31.
- Reported returns fell from 17.07% to 12.00% as the spread over the 7% senior cost narrowed; the reported September 2026 monthly return was 0.50%.
- Zero overdue loans; Qiro attributes this to par buyouts of 60-day-late loans, whose volume is not public.
- Sky's vault debt fell from 36.35 million DAI (May 31) to 15.59 million (October 31) and 9.11 million (November 9).
Key Gaps & Non-Disclosures
- Operating agreement, fee base and redemption discretion not available.
- No fund audit reported in January 2024 and current status unconfirmed; New Silver Lending's financials not public.
- Last Form D sales figure $265,000 (November 2023).
- Par buyout history and the current senior financing not disclosed.
Platform Intelligence
New Silver timeline
Key platform events, regulatory turns, liquidity stress points, and product launches that shape how the review should be read.
Massachusetts complaint; New Silver founded
January: the Massachusetts Securities Division files against Kirill Bensonoff and Caviar over an unregistered coin offering. New Silver Lending is founded in 2018.
Consent order
February 26: consent order settles the Massachusetts matter (cease and desist, rescission offered, disgorgement, $50,000 penalty), without admission.
NS Pool LLC
November: New Silver applies to Centrifuge as an issuer. December: NS Pool LLC files a Form D ($125,044 sold, 5 investors).
First MakerDAO real-world vault
April: RWA-002 (New Silver Series 2 DROP) goes live, 20 million DAI ceiling.
Fund launched
May: DeFi Securitized Mortgage Fund LLC files a Form D: $265,000 sold to 3 investors of $20 million offered.
Maker restructuring; fund renamed
July: Maker governance approves a 50 million DAI ceiling and a 7% stability fee; August: trust indenture with Ankura. November: Form D/A records the name New Silver Income Fund, LLC, still $265,000 sold.
Form ADV; Fortress
January: Form ADV lists the fund at $1,592,896 gross assets, 8 owners, no annual audit. November: Fortress forward flow agreement to buy New Silver loans.
12.00% year
Stated return 12.00%; monthly distributions begin in July. Qiro: equity about $10.3 million at FY2025.
Spread at the hurdle; vault shrinking
May: Qiro puts the junior return 'at the preferred return threshold'; vault debt 36.35 million DAI on May 31. September: reported monthly return 0.50%. Vault debt 27.11 million on August 31, 15.59 million on October 31 and 9.11 million on November 9.
Investor Operations
The practical questions investors actually care about: when tax documents arrive, how cash distributions work, and whether capital can be exited before the underlying asset is sold.
Tax Documents
K-1 Timing
What to expect
Not stated.
Delay signals
- No public statement on K-1 timing
Extension risk
Not stated.
Confidence: Low
Cash Flow
Distributions
Timing
Monthly since July 2025, per New Silver.
Consistency
Reported monthly returns of 1.00% through August 2026 and 0.50% for September 2026 (New Silver's figures; no record of the cash distributions).
Liquidity
Exit Reality
Holding period
None stated; redemptions quarterly with 60-day notice and 90-day payout.
Exit options
- Quarterly redemption request, capped at 5% of NAV per quarter
Secondary market
No market for the units.
Confidence: High
Investment Structures
Open-ended private credit fund (Rule 506(c)), junior tranche
Class B units of New Silver Income Fund, LLC, accredited investors only, $50,000 minimum, $20 million maximum offering. The fund holds the junior, first-loss tranche of NS Pool LLC's pool of New Silver's short-term first-lien loans; Sky lends the senior tranche at a 7% stability fee. Marketed: 12% preferred return paid monthly, 12% to 14% net target, 90/10 split above the pref, management fee 1.75% to 0.75% by investment size, quarterly redemptions (60-day notice, 90-day payout, 5% of NAV cap), Schedule K-1.
Risk
Risk Structure
This is where the marketplace pitch gives way to the actual operating reality: delayed exits, limited disclosure, fee drag, and path-dependent outcomes.
First-loss position
The fund holds the pool's junior tranche; losses reach it before Sky's senior position. Qiro puts the effect at about five times the portfolio default rate at the junior level.
Senior facility set by governance
Sky's governance sets the 7% stability fee and the vault's ceiling, and Maker may request redemption at any time; the vault's debt fell from 36.35 million DAI on May 31 to 9.11 million on November 9, 2026.
Lender support
Qiro describes par buyouts of 60-day-late loans; the memorandum says New Silver 'will seek to' repurchase. The obligation, the buyout volume and New Silver Lending's finances are not public.
Thin spread
8.82% portfolio yield against a 7.00% senior cost (May 2026) left the junior return at the 12% hurdle; the reported September 2026 monthly return was 0.50%.
Limited liquidity
Quarterly redemptions capped at 5% of NAV with 60-day notice and 90-day payout; suspension rights not in the memorandum.
Disclosure
Thin offering terms, no fund audit reported in January 2024, last Form D figure from 2023, two return series that differ.
Leverage on a thin spread
A 1.82% pool spread over a 7% senior cost carries the 12% junior return; a 2% default rate at 50% severity breaks it (Qiro).
Why it matters
Small changes in loan yields, defaults or the senior fee move the junior return several times over, and the reported September 2026 monthly return was half the earlier pace.
Mitigation / verification
Ask for the current portfolio yield, senior cost and the junior return they imply, and for the operating agreement's treatment of unpaid preferred return.
A loss record that rests on the lender
Zero overdue loans, which Qiro attributes to New Silver buying 60-day-late loans out of the pool at par.
Why it matters
If defaults rise when the lender is also under pressure, the buyout may stop and losses reach the junior tranche first.
Mitigation / verification
Ask for the buyout history (count, amounts, recoveries) and New Silver Lending's audited statements.
A changing senior facility
Sky's vault debt fell from 36.35 million DAI on May 31 to 9.11 million on November 9, 2026, read on chain at month-ends.
Why it matters
The fund's returns depend on cheap senior money; a smaller or costlier facility changes the economics, and the replacement is not disclosed.
Mitigation / verification
Ask what finances the senior tranche today, at what rate, and whether Sky has signalled a wind-down.
Thin formal disclosure
Thin offering terms, no fund audit reported in January 2024, a last Form D figure of $265,000, and two return series that differ.
Why it matters
Investors have little documentary basis to check returns, fees or redemption rights.
Mitigation / verification
Obtain the operating agreement, subscription agreement and the latest fund financial statements before investing.
Biggest Misconceptions & What Actually Happens
- '100% First-Lien Secured': true of the loans; the investor holds the junior tranche of the pool that owns them.
- 'Fixed 7%': Sky's stability fee, a governance parameter (3.5% until 2023).
- 'Preferred return, paid monthly': a hurdle for the manager's share; the reported September 2026 monthly return was 0.50%.
- 'No lockup period': redemptions are quarterly, capped at 5% of NAV, with 60-day notice and 90-day payout.
- 'Verified track record': no audit of the returns is public; the fund reported no annual audit on its January 2024 Form ADV.
- 'Institutional validation' from Fortress: Fortress funds buy New Silver loans; they are not investors in the fund.
- 'K-1 (capital gains)' (one-pager): the fund's income is loan interest; the basis is not stated.
Regulatory & Legal Posture
Security Status
Units of New Silver Income Fund, LLC are securities sold under Rule 506(c) of Regulation D to verified accredited investors.
The fund's Form D claims exemption 06c and lists Kirill Bensonoff and Alex Shvayetsky as executive officers; New Silver Lending is a Connecticut exempt reporting adviser and reports the fund on its Form ADV.
Disclosure Quality
A short memorandum, a site and a portal page; the operating agreement and subscription documents were not available to AltStreet.
Custody Model
Investors subscribe through CashFlow Portal into the fund; the fund holds junior tokens of NS Pool LLC, whose loans are pledged to Ankura Trust Company as indenture trustee; FCI Lender Services collects loan payments.
Regulatory Backing
No custodian, administrator or auditor is named for the fund itself.
Tax Treatment
Reporting
Schedule K-1.
Not stated.
Income Character
Interest income from the pool's loans, passed through the partnership.
The Q2 2026 one-pager describes the K-1 as 'K-1 (capital gains)'; a fund holding a loan pool's junior tranche earns interest, and no basis for the claim is given.
Limitation
Confirm the character of income with a tax adviser and the fund's tax counsel before relying on capital gains treatment.
Account Suitability
Taxable
Accredited investors; interest income is likely ordinary.
Roth IRA
Accepted per invest.newsilver.com; check for UBTI from the pool's leverage.
Traditional IRA
Accepted per invest.newsilver.com; check for UBTI.
HSA
Not typical.
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AltStreet Data Layer
What the data actually shows
AltStreet ingested the memorandum, read the fund's and NS Pool's Form Ds and the manager's Form ADV, read Sky's vault on chain, and reconciled New Silver's figures across its memorandum, site, one-pager, portal page and the third-party appraisal published by infiniFi.
Senior vault down three quarters
Sky's RWA002-A vault debt, read on chain at month-ends: 36.35 million DAI (May 31), 38.37 million (July 31), 27.11 million (August 31), 26.85 million (September 30), 15.59 million (October 31), 9.11 million (November 9). On August 31 it funded about 63% of the $43.1 million pool New Silver reported.
What this means
Ask what finances the pool's senior tranche now and at what cost.
Return at the hurdle
Reported returns 17.07%, 15.51%, 12.00% (2023 to 2025); reported September 2026 monthly return 0.50%; Qiro: 8.82% yield vs 7.00% senior cost, 'currently at the preferred return threshold'.
What this means
The 12% is a hurdle, not a guarantee.
Form D far behind the fund
$265,000 sold to 3 investors as the last Form D sales figure (November 2023); $1,592,896 gross assets on the January 2024 Form ADV; about $10.3 million equity at FY2025 per Qiro.
What this means
Sales since 2023 are not in any filing AltStreet located.
Two return series in one table
Monthly figures sum to 18.09% (2023) and 15.90% (2024); the annual column shows 17.07% and 15.51%. The site's ~$44,500 and the memorandum's $53,080 follow the annual column; the one-pager's $30,580 matches neither.
What this means
Ask how each series was calculated and for the investor-level statement behind it.
Data as of 2026-11-10 . AltStreet review evidence layer . Public-source analysis
Full dataset26%
Junior share of the pool (May 2026)
The fund's first-loss tranche, $12.7 million behind Sky's $36.5 million senior position (Qiro).
0.50%
Reported monthly return, September 2026
After 1.00% a month January to August; the 12% preferred return is 1.00% a month.
$265,000
Last Form D sales figure (November 2023)
Qiro gives equity of about $10.3 million at FY2025.
9.1M DAI
Sky's senior vault, November 9, 2026
Read on chain; 36.35 million on May 31 and 15.59 million on October 31.
Decision Fit
Investor Fit
Who this works for, who it does not, and what level of patience and complexity tolerance the platform really demands.
Accredited investors seeking monthly income who can analyze a levered first-loss position
The loans are short and first-lien, but the investor holds the first-loss slice behind a senior lender, with no fund audit public and a spread at the hurdle.
Investors who read '100% first-lien' as senior debt
The fund ranks behind Sky's senior tranche.
Non-accredited investors
Rule 506(c) only.
Tradeoffs
Key Tradeoffs
The attraction of pre-IPO access is real, but every benefit comes bundled with a corresponding liquidity, transparency, or pricing cost.
Yield vs. position
A 12% target comes from holding the first-loss tranche of a pool funded mostly by a senior lender.
Zero losses vs. lender support
The zero-loss record is attributed to New Silver buying late loans out at par, an arrangement whose terms and volume are not public.
Liquidity vs. gates
No lockup, but redemptions are quarterly and capped at 5% of NAV.
Avoid
Who This Is Not For
This section should be read as a filter, not an afterthought. If you need income, simplicity, or near-term access to capital, the structure is working against you.
Non-accredited investors
Rule 506(c) only.
Investors who want senior secured debt
The fund holds the junior tranche.
Investors who need audited reporting
The fund reported no annual audit on its January 2024 Form ADV, and current audit status is unconfirmed.
Editorial View
AltStreet Perspective
The compressed version of the review: what matters, what marketing tends to obscure, and how we would frame the platform for a serious allocator.
Verdict
A lender-sponsored first-loss fund whose 12% target depends on a narrowing spread over Sky's 7%, a shrinking senior vault and the lender's support for late loans.
Positioning
Ask for the operating agreement, audited statements, the par buyout history and the current senior financing before investing.
The Bottom Line
First-lien loans, first-loss position: New Silver's Income Fund levers its own loan pool on Sky.
Action
Next Steps
If you still want to engage after reading the review, these are the practical next moves that reduce avoidable mistakes.
Request the operating agreement and subscription agreement, and read the redemption, distribution and fee sections.
Ask whether the fund is now audited and for New Silver Lending's financial statements.
Ask what finances the senior tranche after the fall in Sky's vault, and at what cost.
Ask whether the par buyout is a contractual obligation, for its history, and why the reported September 2026 monthly return was 0.50%.
Ask how the monthly and annual return series in the track record were each calculated.
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Deal Intelligence →Appendix
Sources, Disclosures, and Supporting Context
The lower section is structured like a report appendix: relationship context first, adjacent reading second, and evidence last.
Report Appendix
Disclosure
Relationship and compensation context
+
Report Appendix
Disclosure
Relationship and compensation context
Report Appendix
Related Resources
Adjacent platform comparisons, frameworks, and category links
+
Report Appendix
Related Resources
Adjacent platform comparisons, frameworks, and category links
Further Reading
Related Resources
Adjacent frameworks and reviews that help place the platform in a broader allocation or due-diligence context.
Explore Asset Class
Private Credit / Residential Bridge Loans (Junior Tranche)Similar Platform Reviews
- Groundfloor
Retail fix-and-flip loans sold note by note under Regulation A.
- Iron Bridge Mortgage Fund
An unlevered first-lien bridge-loan fund with a long public record.
- DLP Capital
Lender funds with related-party loans and a stated preferred return.
Report Appendix
Evidence & Methodology
30 cited passages on file; sources, scope, and how the review was assembled
+
Report Appendix
Evidence & Methodology
30 cited passages on file; sources, scope, and how the review was assembled
Evidence on file
30 supporting passages on file for New Silver and its offerings from 14 source documents, 12 discrepancies flagged. Each passage records the metric it supports, the value read from the document, the page, and the verbatim text where the document has it. Terminal subscribers read the passages; open them in the terminal.
- Cited passages
- 30
- Source documents
- 14
- Analyst verified
- 0
- Discrepancies flagged
- 12
ASReview Evidence
Methodology
The Q4 2026 offering memorandum ingested in full; Firecrawl captures of capital.newsilver.com, invest.newsilver.com, newsilver.com and the CashFlow Portal offering page; the Form D notices of the fund and NS Pool LLC read from XML; New Silver Lending's Form ADV PDF (rendered for checkbox answers); the Massachusetts administrative complaint; Maker forum, poll and on-chain records for RWA002-A; Centrifuge forum records; documents infiniFi publishes on GitHub (Qiro appraisal, one-pager, monthly updates); Fortress's release; CourtListener. No account was opened and the operating agreement was not available.
Scope
New Silver Income Fund, LLC and the pool it invests in; New Silver Lending's adviser record and principals' regulatory history.
Key Findings
- *Qiro capital stack (May 2026): senior facility 7.00%; Sky $36.5 million (73.93%), junior $12.7 million (26.07%), minimum 20%.
- *Qiro: 'any loan reaching 60+ days past due is purchased by the operating entity at par.'
- *Qiro: 'At 5x leverage, each 1% of portfolio default translates to a 5% impact on junior tranche capital.'
- *capital.newsilver.com track record, 2026: '1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 0.50'.
- *Form ADV Schedule D: 'Are the private fund's financial statements subject to an annual audit?' No.
- *Form ADV Item 11: 'PENALTY OF $50,000 PAID ON FEBRUARY 26, 2019.'
Primary Source Pages
FAQ
Frequently Asked Questions
High-intent search questions answered directly, without making users hunt through the full review.
What is New Silver?
New Silver Lending LLC is a West Hartford, Connecticut lender to real estate investors (fix-and-flip, construction and rental loans), founded in 2018 by Kirill Bensonoff and Alex Shvayetsky. Its investor brand, New Silver Capital, offers one product: the New Silver Income Fund, LLC.
What does the New Silver Income Fund invest in?
The junior tranche of NS Pool LLC, New Silver's own subsidiary that buys its loans. Sky (formerly MakerDAO) holds the senior tranche through vault RWA002-A at a 7% stability fee; in May 2026 the split was $36.5 million senior and $12.7 million junior (Qiro). The fund takes losses before Sky does.
Is the 12% return guaranteed?
No. The 12% preferred return is a hurdle before the manager's 10% share. Reported returns fell from 17.07% (2023) to 12.00% (2025); reported monthly returns ran at 1.00% through August 2026 and 0.50% for September. Qiro's May 2026 appraisal described the junior return as 'currently at the preferred return threshold'.
Has the fund ever had a loss?
New Silver reports none and no overdue loans. Qiro attributes this to New Silver Lending buying any loan 60 days past due out of the pool at par; the memorandum says New Silver 'will seek to' repurchase or replace such loans. Whether that is a contractual obligation, how many loans have been bought out, and the lender's finances are not public.
Is New Silver legit?
The lender is real and established: it has financed loans through MakerDAO since 2021 under public governance records, and Fortress agreed to buy its loans in 2024. The concerns are about the fund's disclosure: short offering terms, no audit reported on its January 2024 Form ADV, a last Form D sales figure of $265,000 (November 2023), a return table with two series that differ, and a 2019 Massachusetts consent order against the CEO that the fund's materials omit.
What fees does the fund charge?
A management fee tiered by investment size (1.75% under $150,000, 1.50%, 1.00%, 0.75% at $1 million and over) and 10% of profit above the 12% preferred return, paid at year end. The fee base and fund expenses are not stated, and New Silver Lending also earns origination economics on the loans.
How do redemptions work?
Quarterly, with 60 days' notice and payment within 90 days, capped at 5% of NAV per quarter. The memorandum does not say whether the manager can suspend redemptions; the operating agreement was not available.
What was the Massachusetts action against Kirill Bensonoff?
In January 2018 the Massachusetts Securities Division alleged that Bensonoff and Caviar sold an unregistered token to fund a crypto and residential flip loan pool. It was settled by consent order on February 26, 2019, without admitting or denying: cease and desist, rescission offered, disgorgement and a $50,000 penalty. New Silver Lending discloses it on its Form ADV; New Silver has described Caviar as a separate venture that refunded its investors.
Is the fund audited?
New Silver Lending's January 29, 2024 Form ADV answered 'No' to whether the fund's statements were subject to an annual audit, and no later Form ADV is on file, so current audit status is unconfirmed. The fund's materials name no auditor.