New Silver Lending Review 2026: Rates, the MakerDAO Credit Line and What Federal Data Shows
Quick Answer
New Silver Lending LLC is a real, small, tech-driven private lender based in West Hartford, Connecticut (not Miami), NMLS 2154545, founded in 2018 by Kirill Bensonoff and Alex Shvayetsky. It advertises fix-and-flip loans at 8.5% to 11% with 1% to 1.75% origination, up to 90% of cost and 75% of after-repair value, and DSCR rental loans “from 6%”. The best public record of what its borrowers actually paid is not on its website but in its own monthly reports to MakerDAO (now Sky), which has lent against its loans since April 2021: from December 2021 to May 2023 the monthly average note rate on loans placed in that pool ran 8.7% to 9.8% (one month printed “10/4%”), average loan-to-value 42% to 75%, with 130 loans placed in 2022 alone (11 monthly reports, our arithmetic) and zero loans 90+ days late or in foreclosure in every report. On October 6, 2026 the Sky vault still carried 28,642,657 DAI of debt against a 50 million ceiling (57.3% used, our arithmetic from on-chain data). Its two SEC Form D investor offerings raised little: $125,044 from 5 investors (NS Pool LLC, 2020) and $265,000 of a $20 million target from 3 investors (New Silver Income Fund, last reported November 9, 2023). New Silver does not appear on any HMDA filer list for 2022 to 2025, so there is no federal loan-level record of its rates, and the CFPB database lists 2 complaints. As of October 6, 2026.
Key Takeaways
- Who it is: New Silver Lending LLC, 28 N Main St, West Hartford, CT, NMLS 2154545, founded 2018. Its website says 40 states; its llms.txt file says 42 jurisdictions. It describes itself as a direct lender that “does not operate as a broker.”
- What it advertises (October 6, 2026): fix and flip 8.5% to 11%, 1% to 1.75% origination, 90% LTC, 75% loan-to-ARV, 650 minimum FICO; DSCR from 6%, 0.75 minimum ratio, 80% LTV, 660 FICO; ground-up 9.75% to 11.25%. Its own llms.txt file, updated February 6, 2026, gives different floors: 9.00% for fix and flip, 5.875% for DSCR, 10.25% for ground-up.
- What pool borrowers paid: New Silver's monthly MakerDAO reports show average originated rates of 8.7% to 9.8% (October 2022 printed as “10/4%”), average FICO 688 to 737 and average LTV 42% to 75% from December 2021 to May 2023. In 2020 it told MakerDAO it charged 10.875% to 13%.
- Where the money comes from: a MakerDAO/Sky vault (RWA-002) opened in April 2021, raised from 5 million to 20 million and then to a 50 million DAI ceiling in a restructuring that went live at the end of August 2023, with Ankura Trust as trustee. On-chain debt on October 6, 2026: 28,642,657 DAI. Sky's Q2 2026 report says “All covenants are passing.”
- SEC filings: three Form Ds. NS Pool LLC (the vault's issuer) sold $125,044 of debt to 5 investors in 2020. The DeFi Securitized Mortgage Fund, renamed New Silver Income Fund, sought $20 million and reported $265,000 from 3 investors (1.3%, our arithmetic); its 2022 launch release targeted a 17-22% yield.
- Federal data gaps: New Silver is on none of the HMDA filer lists for 2022 to 2025, so its rates cannot be checked in federal loan-level data. CFPB complaints: 2 (a 2025 foreclosure complaint from Georgia tagged Servicemember, and a 2026 payoff complaint from Florida). Rental loans, it said in 2022, were originated by partner lenders.
CSV · 250 rows
New Silver Lending: MakerDAO pool reports, on-chain vault debt, SEC Form D filings, advertised terms, HMDA and CFPB
250 rows: New Silver's monthly MakerDAO/Sky pool reports for December 2021 to May 2023 and July to November 2024, the RWA-002 vault terms and covenants, the vault's on-chain debt on October 6, 2026, three SEC Form D filings, New Silver's published loan terms and 30 showcase loans, its HMDA filer-list status with the Regulation C rules, and its CFPB complaints.
Who New Silver is
New Silver Lending LLC is a Delaware company headquartered at 28 N Main St, West Hartford, Connecticut, according to its about page. It lends in Florida, but its headquarters and its SEC filings are in Connecticut. Kirill Bensonoff is CEO and Alex Shvayetsky is co-founder and head of risk. The site footer gives NMLS Company ID 2154545.
It makes four kinds of loan: fix-and-flip (bridge) loans, ground-up construction loans, 30-year DSCR rental loans and, since a September 15, 2025 press release, small-balance commercial loans of $2 million to $15 million. In a July 7, 2026 interview summary sponsored by New Silver on Private Lender Link, the company put its recent mix at roughly 40-50% fix and flip, 20% DSCR and 30-40% new construction, and said the commercial multifamily pilot was “temporarily paused.” Its llms.txt file, last updated February 6, 2026, still lists commercial loans.
Our September 27, 2026 legitimacy check of 20 DSCR lenders covers the license basics. This page adds the records the company itself filed with MakerDAO and the SEC.
What New Silver advertises
From New Silver's product pages and home page, read October 6, 2026 (the lender says):
| Term | Fix and flip | DSCR rental | Ground-up construction |
|---|---|---|---|
| Interest rate (product page) | 8.5% to 11% | From 6% | 9.75% to 11.25% |
| Interest rate (llms.txt, February 6, 2026) | 9.00% to 11.00% | From 5.875% | 10.25% to 11.25% |
| Origination fee | 1% to 1.75% | 0% to 1.5% (0% to 2% on the home page card) | 1% to 2% |
| Leverage | Up to 90% of cost, 75% of ARV, 100% of rehab | Up to 80% LTV, minimum DSCR 0.75 | Up to 90% of cost, 75% of ARV |
| Minimum FICO | 650 | 660 | 650 |
| Loan size | $100,000 to $5,000,000 | $150,000 to $3,000,000 | $100,000 to $5,000,000 |
| Term | Up to 18 months | 30-year fixed | 18 months |
| Experience required | No | No | Not stated |
Speed claims differ by page: “Close in 7 Days” on the product card, “10 days Average time to close” on the home page and “funding in as little as 5 days” on the about page. The home page also says “$1 billion+ In Applications Processed” and an over-50% repeat borrower rate; applications are not loans, and the site gives no total of loans funded. The last funded totals we found are the company's own: “over $30mm” by mid-2020 (MakerDAO application) and “more than $90 million” by February 23, 2022 (press release).
The pages also show 30 undated “recently funded” loans chosen by the lender. The median rate of the 10 fix-and-flip examples is 9.5% (range 7.00% to 10.50%), of the 10 ground-up examples 10.75% (10.25% to 11.25%) and of the 10 rental-page examples 6.5% (5.875% to 8.375%), our arithmetic. One fix-and-flip example, $121,800 in Rockford, Illinois at 7.00%, sits below the advertised 8.5% floor.
What its borrowers actually paid: the MakerDAO pool reports
New Silver was the first real-world-asset borrower in MakerDAO, the issuer of the DAI stablecoin, now renamed Sky. Its special-purpose vehicle, NS Pool LLC, buys New Silver's loans and issues senior (DROP) and junior (TIN) tokens on the Centrifuge platform; the vault lends DAI against the senior tokens. From December 2021 to May 2023 New Silver posted a monthly update on the Maker governance forum with figures for the loans it put into that pool. We collected all 16 we could find.
| Month | New loans in pool | Volume | Avg. note rate | Avg. LTV | Avg. FICO |
|---|---|---|---|---|---|
| Dec 2021 | 16 | $3.7M | 8.7% | 64% | 722 |
| Jan 2022 | 13 | $4.42M | 8.7% | 58% | 700 |
| Mar 2022 | 14 | $4.4M | 9.1% | 72% | 716 |
| May 2022 | 16 | $3.86M | 9% | 71% | 699 |
| Jul 2022 | 7 | $1.45M | 9.6% | 75% | 737 |
| Oct 2022 | 5 | $1M | printed “10/4%” | 42% | 734 |
| Nov 2022 | 12 | $2.9M | 9.8% | 57% | 708 |
| Jan 2023 | 16 | $3.9M | 9% | 57% | 688 |
| Apr 2023 | 23 | $6.5M | 9.5% | 57% | 692 |
| May 2023 | 4 | $937,000 | 9.4% | 66% | 709 |
The CSV has all 16 months. Across the 11 monthly reports for 2022 (September is missing), New Silver placed 130 loans for about $32.7 million in the pool (our arithmetic). Every report from December 2021 to May 2023 shows 0 loans 90+ days late, 0 in forbearance and 0 in foreclosure. In November 2022 it wrote that it had “cycled through ~50mm DAI, with no losses.”
Three things in these reports matter to a borrower. First, the rate moved with the market: from 8.7% at the start of 2022 to 9.6% to 9.8% in the second half of the year, against the 10.875% to 13% it quoted to MakerDAO in 2020. Second, the pool is not the whole company: in June 2022, with the vault nearly full, New Silver wrote “we have had to sell newly originated loans to other partners.” Third, its 30-year rental loans were not its own in 2022: rental loans, it told a Maker delegate, “are 30 year fixed mortgages, and we partner with a few institutional lenders that originate those.”
From July to November 2024 the reports changed format. New Silver financed 91 new loans in those five months (our arithmetic); by November 2024 the pool held 125 loans with collateral of 29,321,577 DAI, an average finance fee of 8.45% paid to the pool, junior subordination of 26.6% against a 20% minimum, and 0 events of default.
The vault today, and the rules it runs under
The restructured vault (terms published on the Maker forum by Steakhouse Financial in July 2023) went live at the end of August 2023. Its covenants are a useful outside view of the loans New Silver may put in it:
| RWA-002 term (2023 restructuring) | Value |
|---|---|
| Debt ceiling | 50,000,000 DAI (up from 20,000,000) |
| Stability fee | 7% (up from 3.5%) |
| Minimum junior subordination | 20% |
| Minimum borrower FICO | 625 |
| Maximum loan-to-cost, single loan / weighted average | 90% / 87.5% |
| Maximum loan-to-after-rehab-value, single loan / weighted average | 80% / 75% |
| Maximum loan term | 24 months |
| Maximum single-state exposure | 30% of portfolio |
| Defaulted loans | 100% haircut if unpaid at maturity or interest 60 days delinquent |
| Trustee and verification agent / servicer | Ankura Trust Company / FCI Lender Services |
| Termination date | October 11, 2032 |
We read the vault's state directly from the Maker Vat contract on Ethereum at block 26130785 (October 6, 2026, 03:56 UTC): 28,642,657 DAI of debt against a 50,000,000 DAI ceiling, 57.3% used (our arithmetic). Sky's June 2025 report notes New Silver “paying down its loan by $7M” that month, and its Q2 2026 report says “All covenants are passing and Ankura as Trustee is verifying deal covenants prior to every new loan made by the vault.” For a borrower this means New Silver has a working, verified credit line; for a borrower in the middle of a rehab, it is the line that funds draws.
The SEC filings: two small investor offerings
EDGAR lists three Form D filings tied to New Silver, all signed by Kirill Bensonoff, all under Rule 506(c) (accredited investors only).
| Issuer (accession) | Filed | Securities | Target | Sold | Investors | Minimum |
|---|---|---|---|---|---|---|
| NS Pool LLC (0001835932-20-000001) | Dec 17, 2020 | Debt | Indefinite | $125,044 | 5 | $10,000 |
| DeFi Securitized Mortgage Fund LLC (0001930154-22-000001) | May 19, 2022 | Pooled fund | $20,000,000 | $265,000 | 3 | $50,000 |
| New Silver Income Fund LLC, renamed (0001930154-23-000002) | Nov 9, 2023 | Pooled fund (amendment) | $20,000,000 | $265,000 | 3 | $50,000 |
The 2022 fund was launched with a paid press release on February 23, 2022 that said it “has a 14% hurdle rate and aims to return a 17-22% yield annually” by investing in loans “securitized on the blockchain.” Its Form D shows the first sale on May 3, 2022 and, in the November 2023 amendment, the same $265,000 from 3 investors, 1.3% of the target (our arithmetic). No later Form D appears for either entity as of October 6, 2026. We found no rated securitization of New Silver loans; the Centrifuge/Maker structure is the only securitization the company describes.
If you were offered an investment in a New Silver fund, our PeerStreet case shows what happens to fractional real-estate debt when a platform's funding dries up. That is context, not a prediction about New Silver.
Federal records: no HMDA, two CFPB complaints
The Home Mortgage Disclosure Act data set is the only public loan-by-loan record of what lenders charge. New Silver, NS Pool LLC and any “New Silver” name are absent from all four FFIEC HMDA filer lists we checked (2022: 4,483 institutions; 2023: 5,135; 2024: 4,927; 2025: 4,789), and neither company has a legal entity identifier in GLEIF.
Why it is absent is not something the public record answers. Regulation C does cover some short investor loans: its official interpretation gives the case of a nine-month loan to an investor to buy, renovate and resell a home and says “Such a transaction is not temporary financing under § 1003.3(c)(3) merely because its term is short.” But the rule also has volume thresholds, exclusions for some business-purpose and temporary loans, and a provision under which, when a buyer makes the credit decision before closing, the buyer reports the loan rather than the company whose name is on the closing documents. Which of these applies to New Silver's loans cannot be seen from outside, and we did not ask New Silver for this version. The practical result for a borrower is that no federal data show what New Silver charged, so its MakerDAO reports are the best evidence there is.
The CFPB Consumer Complaint Database lists 2 complaints naming New Silver Lending LLC: February 5, 2025 from Georgia, “Struggling to pay mortgage” / “Foreclosure”, tagged Servicemember, to which the company responded that it “believes it acted appropriately as authorized by contract or law”; and April 8, 2026 from Florida, “Trouble during payment process” / “Paying off the loan.” Both were closed with explanation and answered on time. Business-purpose borrowers rarely file with the CFPB, so this is a floor.
We could not run a court search: CourtListener's API was throttled for us on October 6, 2026, and Connecticut's civil case search sits behind a bot check. NMLS Consumer Access sits behind a captcha. A lender that forecloses on defaulted flip loans will have court cases; check your own state's docket for “New Silver Lending” before you sign if that matters to you.
What a borrower can do with this
- Use the pool rates as your benchmark, not the floor. New Silver's own 2022 pool averages were 8.7% to 9.8%; its showcase fix-and-flip loans center on 9.5%. A first quote near 8.5% is possible but is the exception in its own data. Get a written term sheet before you pay for the appraisal.
- Ask which lender closes and holds your loan. For a DSCR loan, ask whether New Silver or a partner lender is the lender of record and who will service it; in 2022 it said partners originate its rental loans. For a flip loan, ask whether it will sit in the Sky pool (serviced by FCI Lender Services) or be sold.
- Get draw, extension and default terms in writing. The vault haircuts any loan that is unpaid at maturity or 60 days behind on interest, which gives New Silver a reason to act quickly on late loans. Know the extension fee and the default rate before closing.
- Check the leverage you are actually offered. The pool covenants cap single loans at 90% of cost and 80% of after-rehab value; the advertised 75% of ARV is the usual ceiling.
- Compare two other lenders on the same deal on the same day. Our best fix-and-flip lender comparison and Kiavi review cover the larger names.
FAQ
Sources, read October 6, 2026: SEC EDGAR Form D filings 0001835932-20-000001 (NS Pool LLC), 0001930154-22-000001 and 0001930154-23-000002 (DeFi Securitized Mortgage Fund LLC / New Silver Income Fund LLC) and the EDGAR submissions API; New Silver's monthly updates and reports on the Maker governance forum (December 2021 to May 2023, July to November 2024), its 2020 MIP6 application and 2022 debt-ceiling request, Steakhouse Financial's July 2023 risk and legal assessment of RWA-002 and its RWA reports for December 2023, June 2025 and Q2 2026; the Maker Vat contract on Ethereum mainnet (ilk RWA002-A, block 26130785); the FFIEC HMDA filer lists for 2022 to 2025 and GLEIF; Regulation C, 12 CFR 1003.2, 1003.3 and Supplement I (eCFR); the CFPB Consumer Complaint Database; New Silver's home, about, fix-and-flip, DSCR, ground-up and commercial pages and llms.txt; its February 23, 2022 and September 15, 2025 press releases and November 2, 2021 blog post; and a July 7, 2026 Private Lender Link interview summary sponsored by New Silver. Sums, medians, shares and the vault utilisation are our arithmetic. DAI is a dollar-pegged stablecoin; DAI figures are not converted. This is analysis of public documents, not investment, legal or tax advice.
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