United States securities and exchange commission logo
May 24, 2021
Hunter Horsley
President
Bitwise 10 Crypto Index Fund
300 Brannan Street, Suite 201
San Francisco, CA 94107
Re: Bitwise 10 Crypto
Index Fund
Registration
Statement on Form 10
Filed April 23,
2021
File No. 000-56270
Dear Mr. Horsley:
We have reviewed your registration statement and have the
following comments. In
some of our comments, we may ask you to provide us with information so
we may better
understand your disclosure.
Please respond to this letter by amending your registration
statement and providing the
requested information. If you do not believe our comments apply to your
facts and
circumstances or do not believe an amendment is appropriate, please tell
us why in your
response.
After reviewing any amendment to your registration statement and
the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form 10
General
1. Please revise your
filing to include a glossary of defined terms. Additionally, we note
references to the Trust
s Portfolio Crypto Assets per Share and also references to Net
Asset Value per Share.
Please clearly define these measures and, if the same, please revise
your filing for
consistency.
2. Please revise to
include and clearly label a Management s Discussion and Analysis of
Financial Condition and
Results of Operations section in your filing for each period
presented. Refer to
Item 303(a) of Regulation S-K.
3. You state that the
Trust s principal investment objective is to invest in a portfolio of
cryptocurrencies that
tracks the Bitwise 10 Large Cap Crypto Index as closely as
Hunter Horsley
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Bitwise 10 LastNameHunter
Crypto Index FundHorsley
Comapany
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possible. Please discuss in your registration statement the extent to
which the Trust has
met its principal investment objective in light of the difference
between the trading price
of the shares on the OTCQX as compared to the Trust's net asset value
per share.
Business
History of the Trust and the Shares, page 1
4. We note your disclosure on page 1 that the price of the shares as
quoted on the OTCQX
has varied significantly from the value of the Trust's Portfolio
Crypto Assets per Share
since the shares were approved for quotation. Please provide
quantitative disclosure to
demonstrate the historical difference between the prices quoted on the
OTCQX and the
NAV of the Trust's Portfolio Crypto Assets per Share. Please also
revise the first risk
factor on page 44 accordingly.
Emerging Growth Company Status, page 2
5. We note disclosure that you are choosing to opt-out of the extended
transition period for
applying new or revised accounting standards. Please revise the facing
page of your filing
to check the box indicating your election to not use the extended
transition period for
complying with new or revised financial accounting standards.
Activities of the Trust, page 3
6. We note your disclosure on page 4 that the activities of the Trust
include selling or buying
Portfolio Crypto Assets in connection with monthly rebalancing and
selling Portfolio
Crypto Assets to cover the Sponsor's Management Fee. Please disclose
the principal
market the Trust uses to convert digital assets to U.S. dollars and to
purchase digital assets
in connection with a sale of shares or in connection with the monthly
rebalancing of the
Portfolio Crypto Assets.
Business of the Trust, page 3
7. We note your disclosure on page 3 that the Trust provides investors
with a cost-effective
and professionally managed way to invest in digital assets. Please
revise to clarify that an
indirect investment in digital assets through your shares may operate
and perform
differently from a direct investment in digital assets, and summarize
the material
differences. In addition, please disclose here the expenses of the
Trust, including the
Sponsor's fee of 2.5% per annum.
Index, page 4
8. Please clarify the roles of the Bitwise Crypto Committee and the
Bitwise Crypto Index
Advisory Board in the governance of the Index. In this regard, we note
your disclosure on
page 4 that the components of the Index's methodology are subject to
change in the sole
discretion of the Sponsor, that the Sponsor and its affiliates select
the exchanges used by
the Index and that additional eligibility criteria may be developed by
the Sponsor and its
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Crypto Index FundHorsley
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affiliates to screen for investment feasibility in selecting the top
ten largest
cryptocurrencies for the Index. Also disclose the factors that may
cause the Sponsor to
modify the Index's methodology, and describe any changes that have
been made to
the Index's methodology since the inception of the Index. Finally,
please
provide an analysis as to why you believe that, as a reporting company
under the
Exchange Act, you are not required to notify shareholders of changes
in Index
methodology or composition. Please revise here and the second risk
factor on page 42
accordingly.
9. Please add a separate subsection to describe how and when the Index is
rebalanced on a
monthly basis and how the Trust adjusts its holdings to track the
Index.
10. You state that you have described "certain aspects" of the Index
methodology. Please
revise this statement and your disclosure regarding the Index to
confirm that you have
provided a materially complete description of the Index and its
methodology.
Investment strategy, page 4
11. Please describe how the Sponsor manages costs and price slippage
during trade
execution.
12. Your disclosure on page 4 that "[u]pon the occurrence of Network
Distributions like hard
forks, airdrops, emissions, staking, or other one-off events, the
Trust will follow the
policies of the Index" appears to be inconsistent with your disclosure
on page 7 "[t]hat
there may be opportunities for the Trust to generate returns in excess
of the Index through
airdrops and proof of stake which the Sponsor will endeavor to do
where possible and
prudent." Please revise for consistency, and disclose how generating
returns in excess of
the Index is consistent with your investment strategy, including your
disclosure that you
are a passive investment vehicle. In addition, please disclose how the
Trust will inform
investors of how these activities will impact the value of the Trust.
Also, please clearly
describe the Sponsor's policies regarding airdrops, including the
criteria for accepting an
airdrop and how the Sponsor capitalizes on such airdrops.
13. We note your disclosure that the Sponsor uses the assets of the Trust
for staking. Please
identify the digital assets it uses for staking and whether it uses a
third party for its staking
activities. Please clarify whether the Sponsor maintains custody of
the staked assets and
whether the staked assets could impact the monthly rebalancing of the
Trust's assets. In
addition, please add a risk factor that addresses the risks associated
with using the Trust's
assets for staking activities.
14. Please also revise your filing to disclose the following:
Disclose your accounting policy for staking;
Disclose whether you have performed any staking services during
any period
presented; and
Quantify the associated revenues earned and any expenses
incurred for each period
Hunter Horsley
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Comapany
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presented.
Index Methodology, page 5
15. Please discuss in detail how the composite prices of the digital
assets in the Index
are determined by applying the trade-volume weighting technique and
the price deviation
analysis. To the extent useful to understanding how the prices of the
Index's digital assets
are determined, please consider including an illustrative example.
16. We note your disclosure on page 5 regarding the public exchanges the
Sponsor selects to
calculate the value of the digital assets included in the Index.
Please clarify what you
mean by "regulatory compliance," and describe how the Sponsor
determines the
"regulatory compliance, security and reliability of real-time price
and trade volume
information and absence of abnormal withdrawal restrictions of crypto
and fiat
currencies" of public exchanges. In addition, please identify the
exchanges that the
Sponsor currently uses in order to calculate the value of the digital
assets included in the
Index, and clarify what you mean by "legitimate public exchanges" on
page 6.
17. We note your disclosure that the ten coins in the Index may not always
match the top 10
coins on popular websites like CoinMarketCap.com that do not use the
Index's screening
methodology. For each of the screening criterion, please identify
those coins that would
be part of the Index based on their total market capitalization but
for the particular
criterion.
Bitwise Crypto Index Committee, page 6
18. You state that the Index is evaluated and studied on an "ongoing
basis" by the Bitwise
Crypto Index Committee. Please revise to clarify whether the Committee
has any
recurring or standing meetings to consider the Index and its
constituent assets and the
frequency of those meetings.
One-Off Events, page 6
19. Please provide detailed disclosure here regarding the Index's
provisions for Network
Distributions events. In addition, please define the term "emissions."
20. We note your disclosure of one-off events, which includes references
to trade suspensions,
hard forks and other network distribution events such as
emissions, airdrops, and
staking. We also note disclosure on page 4, which states that for
one-off events the Trust
will follow the policies of the Index. Please revise the Index
Methodology section and
other relevant sections of your filing to include your accounting
policies related to each of
these one-off events, including how and when these assets are
initially recognized,
distributed, transferred or abandoned, as applicable, and disclose the
impact of these
decisions on your investors. Please also disclose the fair value of
any of these assets held
along with any other financial statement impact as a result of these
one-off events for all
periods presented.
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Crypto Index FundHorsley
Comapany
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Departures from the Index, page 7
21. Please disclose the criteria that the Sponsor will use to determine
whether or not a coin is
fraudulent or otherwise at high risk to shareholders and how the
Sponsor will notify
investors of a change in the types of assets held by the Trust. In
addition, please disclose
the "other assets" the Trust may hold and the factors the Sponsor will
consider in deciding
to hold such assets. Please also disclose whether, and under what
circumstances, the Trust
has differed from the Index in the assets it holds.
22. We note your disclosure that the Trust may differ from the Index in
the coins it holds,
including if the Trust deems a digital asset in the Index to be a
security. However, you
also disclose that the Index will not select a digital asset that is
at risk of being deemed a
security under U.S. federal securities laws. Please clarify whether
the Sponsor's
methodology differs from the Trust's methodology for determining
whether a digital asset
may be a security, and disclose the policies of both the Trust and the
Index if a digital
asset holding is deemed to be at risk of being a security. Please also
reconcile with your
disclosure on page 43 that the Trust intends to avoid investing in
cryptocurrencies that
constitute securities under U.S. securities laws, while the Index has
no such restriction in
its methodology.
Overview of Index Constituents
Overview of Changes to the Index Constituents since December 31, 2020, page 15
23. We note your disclosure that on January 29, 2021 the Bitwise Crypto
Index Committee
added two new constituents to the Index. Please disclose the digital
assets that were
removed and the weight of each of the current constituents as of the
most recent
practicable date. In addition, please explain why the Committee made
this change to the
Index.
Overview of Government Regulation, page 16
24. Please clarify that the Bitwise Framework is not a legal standard and
that any assessment
made under that framework does not preclude legal or regulatory action
based on the
presence of a security. Please also clarify whether the Bitwise
Framework is a risk-based
assessment.
Risk Factors, page 29
25. We note that a substantial majority of the Trust's assets are
concentrated between two
digital assets, Bitcoin and Ether. Please revise to discuss the
specific risks associated with
those two digital assets that are material risks to the Trust's
shareholders.
26. Please include risk factor disclosure describing the risk that the
Index may be unable to
meet its stated purpose of tracking a basket of cryptocurrencies that
represents the
majority of cryptocurrencies by market capitalization if the size of
the constituent assets
continues to decrease relative to the total market capitalization.
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Cryptocurrencies are subject to volatile price fluctuations, page 35
27. Please revise to quantify the volatility of the digital assets in your
portfolio and how that
volatility has impacted an investment in the Trust.
Transactions in cryptocurrencies may be irreversible, page 36
28. We note your disclosure in this risk factor addresses sending
"contributions to the correct
digital wallet address." Please disclose in your business section the
circumstances in
which the Trust will deliver digital assets to shareholders.
The Sponsor is solely responsible for determining the value of Portfolio and
Shares, page 37
29. Your disclosure on page 37 that the Sponsor has not engaged a
third-party calculation
agent is inconsistent with your disclosure on page 77 that Theorem
Trust Services LLC
will calculate the NAV of the Trust and share prices. Please revise
for clarity and
consistency. In addition, please revise your business section to
describe in detail how the
NAV of the Trust, the NAV per share and share prices are calculated as
well as the
exchanges used.
The Bitwise 10 Crypto Index has a fairly limited history, page 42
30. You refer here and elsewhere to the obligations, actions and
discretion of "Bitwise."
Please revise to clarify what entity you are referring to in these
disclosures.
The Trust will not track the Index exactly, page 43
31. Please include a chart here or elsewhere comparing the performance of
the Trust to the
Index.
Risks Related to Trust and Portfolio Investments, page 44
32. Please add a risk factor that discloses the risk that the number of
Portfolio Crypto Assets
represented by a share will gradually decrease over time as the
Trust's Portfolio Crypto
Assets are used to pay the Trust's expenses.
If shareholders enter into share lending arrangement , page 45
33. We note your disclosure on page 45 that the Trust or the Sponsor may
be asked to provide
certain assurances or non-objections to lending arrangements with
response to the Trust's
shares. In an appropriate section of your registration statement,
please disclose the factors
the Sponsor will consider in providing such assurances and
non-objections to such
arrangements.
Shareholders may be required to have their Shares redeemed, page 45
34. Please disclose the situations in which shareholders may be required
to have their shares
redeemed. Please also reconcile the disclosure in this risk factor
with the provision in
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your trust agreement that the Sponsor no longer has discretion to
require redemption. In
addition, please describe what you mean by the reference on pages 62
and 85 to obtaining
regulatory approval to operate a redemption program and clarify that,
under the terms of
your trust agreement, you will not offer a redemption program without
such regulatory
approval, which you may not receive.
35. Please tell us when the prior redemption program ended. Please also
include separate risk
factor disclosure addressing the risk that your prior redemption
program was not
conducted in compliance with Regulation M.
Risks Related to Trading on the OTCQX, page 48
36. Please include a risk factor that describes the effect on investors
who purchase shares in
the secondary market that are trading at a substantial premium over or
a substantial
discount to the NAV per share.
Risks Related to Potential Conflicts of Interest, page 49
37. The three risk factors in this section do not appear to address
conflicts of interest. Please
revise accordingly. In doing so, please address any conflicts of
interest between the
Sponsor and the Trust related to other products or investments of the
Sponsor. In
addition, we note your disclosure on page 5 that Bitwise Index
Services, LLC is an
affiliate of the Sponsor. Please describe here the relationship
between the Index Provider
and your Sponsor and add a risk factor that addresses the risks
related to using an Index
Provider that is affiliated with the Sponsor as well as the potential
conflicts related to the
composition of the Bitwise Crypto Index Committee.
Risks Related to Regulatory and Compliance, page 52
38. We note disclosure that on December 23, 2020 the Trust made the
decision to liquidate its
position in Ripple Labs, Inc., creator of XRP, which prior to the sale
represented 3.8% of
the Fund and proceeds received were reinvested in other portfolio
assets. Please revise
your filing to disclose how this liquidation was reflected in your
financial statements for
the fiscal year ended December 31, 2020.
Financial Information
Management Fee, page 62
39. We note your disclosure on page 62 that the Sponsor is responsible for
paying almost all
ordinary administrative and overhead expenses of managing the Trust.
Please disclose
any of the Trust's expenses that may not be covered by the Management
Fee and disclose
whether or not there is ceiling to the Trust's expenses that the the
Sponsor will pay.
Shareholder Subscriptions, page 62
40. We note your disclosure regarding the days on which the Trust accepts
initial and
additional subscriptions. Please disclose if those are also the days
that in-kind
Hunter Horsley
Bitwise 10 Crypto Index Fund
May 24, 2021
Page 8
subscriptions are valued. In this regard, we note your disclosure on
page 36 regarding the
risk to shareholders if they contribute digital assets to the Trust
due to differences in the
value of the digital assets from the time they are contributed and the
time they are valued
for purposes of determining the number of shares received. In
addition, please provide a
detailed description of how in-kind subscriptions are valued and
whether or not investors
are permitted to withdraw subscriptions after the digital assets are
valued. In this regard,
we note your disclosure on pages 63 and 66.
41. Please disclose whether subscriptions are direct or through an
intermediary. Please also
clarify here and elsewhere whether subscriptions are accepted in
dollars or in-kind or
both. For in-kind subscriptions, please identify the digital assets
you accept. Please also
describe the process by which subscriptions are converted into
Portfolio Crypto Assets,
including when the in-kind investments are converted into Portfolio
Crypto Assets.
42. Please disclose the reasons the Trust may choose to halt the
acceptance of additional
subscriptions for extended periods and if you intend to inform
shareholders that the Trust
has halted acceptance of subscriptions.
43. Please explain how rounding down or up to the nearest whole share will
not change the
price per share.
In-Kind Subscriptions, page 66
44. We note disclosure that you accept digital assets ( In-Kind
Investments ) in lieu of, or in
addition to, cash as payment for investment in the Trust totaling
$99.8 million for the
fiscal year ended December 31, 2020. We also note disclosure on page
47 that the Trust
may distribute in cash or in-kind to satisfy redemption request in the
Sponsor s sole-
discretion. Please revise your filing to disclose your accounting
policy for the acceptance
and distribution of In-Kind Investments. Additionally, please disclose
the following:
A detail of the In-Kind Investments received during fiscal year
December 31,
2020; and
Whether you have made any In-Kind distributions or liquidated a
Shareholder s pro-
rata distribution on their behalf in order to reduce additional
regulatory costs of the
Shareholders for any period presented.
Statement of Operations, page 68
45. We note net realized loss from digital assets of $4.5 million and $3.3
million for the fiscal
years ended December 31, 2020 and 2019, respectively. Please revise your
filing to
FirstName LastNameHunter Horsley
disaggregate realized losses separately for losses due to the sale of
crypto assets as a result
Comapany NameBitwise
of monthly 10 Crypto
rebalancing, lossesIndex Fund of the sale of crypto
assets to pay expenses of
as a result
May 24,the2021
Trust, and8 realized losses related to any other losses.
Page
FirstName LastName
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Bitwise 10 LastNameHunter
Crypto Index FundHorsley
Comapany
May NameBitwise 10 Crypto Index Fund
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Historical Portfolio Crypto Asset Prices, page 70
46. We note your disclosure that Bitwise calculates reference prices daily
by averaging the
prices from select trading venues. Please identify the trading venues
and disclose the
adjustments, if any, Bitwise makes when calculating the average.
Security Ownership of Certain Beneficial Owners and Management, page 73
47. Please update to provide beneficial ownership information as of the
most recent
practicable date, and please add the officers and directors of the
Sponsor to the table.
Please also revise the "Recent Sales of Unregistered Shares" section
on page 84 to
disclose any recent sales as of the most recent practicable date.
Directors and Executive Officers
The Sponsor's Role, page 74
48. On page 74, you state that the Sponsor does not store, hold or
maintain control of the
Trust's Portfolio Crypto Assets. Please revise to clarify that in some
circumstances the
Sponsor will gain control of the Trust's Portfolio Crypto Assets, and
describe each such
circumstance here. In this regard, we note your disclosure on page 30.
In addition, please
disclose whether or not the Sponsor carries insurance for the Trust's
assets.
The Custodian's Role, page 76
49. Please disclose the insurance coverage the Custodian carries for any
losses of the digital
assets that it custodies for you. In addition, please disclose the
material terms of the
custody agreement, including how often the Custodian will send
statements and any audit
or inspection rights you have. Please also include appropriate risk
factor disclosure related
to any material risk of loss associated with the security of the
digital assets with the
Custodian.
Term and Dissolution, page 77
50. Please disclose the events that may cause the dissolution of the
Trust.
Investments by Affiliates, page 81
51. We note your disclosure on page 81 that your affiliates may be subject
to a reduced or no
Management Fee. Please revise to disclose the factors that may
contribute to such a
rebate.
Recent Sales of Unregistered Securities, page 84
52. Please provide us your analysis of the facts and circumstances as
relevant to ascertain
whether or not the private placement investors purchased the shares
with investment intent
and not a view to distribute. In this regard, please tell us any
factors that you consider in
determining the investment intent of the purchasers, in addition to
obtaining a general
Hunter Horsley
FirstName
Bitwise 10 LastNameHunter
Crypto Index FundHorsley
Comapany
May NameBitwise 10 Crypto Index Fund
24, 2021
May 24,
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written representation regarding investment intent. For example,
please tell us whether
you receive any representations from purchasers at the time of
subscription or legend
removal regarding transactions designed to substantially reduce or
eliminate the risk of
their investment, including whether they have taken a short position
at the time of the
private placement investment and intend to cover that position when
the restrictive
legends are removed.
Description of Registrant's Securities To Be Registered, page 86
53. Please disclose all of the material terms of the Trust Agreement,
including the voting
rights of shareholders, the right to bring a derivative action, suit
or other proceeding on
behalf of the Trust, the provisions regarding the removal of the
Sponsor, dissolution and
the ability of the Sponsor to amend the Trust Agreement. In addition,
please disclose that
the provision in the Trust Agreement regarding the right to bring a
derivative action, suit
or other proceeding on behalf of the Trust does not apply to claims
under the federal
securities laws, and add a risk factor that addresses the provisions
regarding the
shareholders' right to bring a derivative action, suit or other
proceeding on behalf of the
Trust.
Transfer Restrictions, page 86
54. Please disclose whether the shareholder must make a request to have
the legend removed.
If not, please explain the reasons for removing the legends in the
absence of request, and
please disclose whether the shareholders are required to make any of
the representations to
outside counsel described in this section or if those representations
come solely from the
Sponsor.
Report of the Independent Registered Accounting Firm, page F-3
55. We note disclosure on page F-4 of the amount of digital assets held by
the Custodian for
each period presented. Please reconcile these amounts to ending
amounts in your
Condensed Schedule of Investments on page F-8 and revise your filing,
where
appropriate, to explain the reason(s) for any digital assets not held
by your Custodian for
each period presented.
Investments and Valuation, page F-13
56. Please revise your filing to disclose how you calculate the net asset
value of the trust in
accordance with GAAP. Please refer to ASC 820-10.
57. We note your disclosure that digital assets are generally valued using
prices as reported on
reputable and liquid exchanges and may involve utilizing an average of
bid and ask quotes
using closing prices provided by such exchanges as of the date and
time of determination.
Additionally, you disclose factors such as the recent stability of the
exchange, current
liquidity of the exchange, and recent price activity of an exchange
will be considered as to
the determination of which exchanges to utilize. Please revise your
filing to discuss the
Hunter Horsley
FirstName
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Crypto Index FundHorsley
Comapany
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exchange(s) that were considered and how you chose the exchange(s)
that were
subsequently selected to determine the principal market and
corresponding fair values for
each of your digital assets.
58. We note your accounting policy disclosure regarding hard forks. Please
revise the relevant
sections of your filing to disclose the following:
A discussion and quantification of the hard forks which have
occurred during the
periods presented differentiated between those which are
recognized due to two or
more recognized exchanges quoting the hard fork compared to those
that that are not
recognized;
Whether there have been hard forks which were not initially
recognized but
subsequently recognized as trust assets;
How you account for hard forks initially upon receipt of a new
digital asset and
subsequently when the hard fork is either retained, liquidated or
ignored by the Index
as disclosed on page 10; and
Disclose the financial statement impact of hard forks received
for all periods
presented.
59. We note your accounting policy disclosure for airdropped digital
assets on page F-14.
Please revise the relevant sections of your filing to disclose the
following:
Explain how you determine whether airdropped digital assets
received have value.
We note disclosure that you will record receipt of airdropped
digital assets when
received if there is value to the Trust in doing so;
How you determined these airdropped digital assets have no cost
basis;
Disclose both airdrops recognized and airdrops not recognized
along with the related
financial statement impact of these airdrops; and
Discuss how you monitor unrecognized airdrops subsequent to
initial receipt.
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
Hunter Horsley
Bitwise 10 Crypto Index Fund
May 24, 2021
Page 12
You may contact William Schroeder at 202-551-3294 or John Spitz at
202-551-3484 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Sonia Bednarowski at 202-551-3666 or Justin Dobbie, Legal Branch Chief,
at 202-551-
3469 with any other questions.
FirstName LastNameHunter Horsley Sincerely,
Comapany NameBitwise 10 Crypto Index Fund
Division of
Corporation Finance
May 24, 2021 Page 12 Office of Finance
FirstName LastName