SEC Company Response from Bitwise 10 Crypto Index ETF (BITW) — Sep 10, 2025
Bitwise 10 Crypto Index ETF
Date: Sept. 10, 2025 · CIK: 0001723788 · Accession: 0001213900-25-086576
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-287889
Letter
Via EDGAR Correspondence United States Securities and Exchange Commission Division of Corporation Finance Office of Crypto Assets F Street, N.E. Washington, D.C. 20549 Re: Bitwise 10 Crypto Index Fund File No. 333-287889
Dear Ms. Cheng and Ms. Paik:
This letter responds to your comment provided telephonically on September 3, 2025 regarding amendment no. 2 to the registration statement filed on Form S-3 for the Bitwise 10 Crypto Index Fund (the “Trust”) with the Staff of the Securities and Exchange Commission (the “Staff”) on August 25, 2025 (the “Registration Statement”). Capitalized terms used herein, but not otherwise defined, have the meanings ascribed to them in the Registration Statement.
Comment 1 – General
The Staff notes the response to prior comment 1 and reissues in part. Please revise to reconcile the inconsistencies between the publicly available information about the Index and the information incorporated by reference to the 10-K. For example, some of the crypto asset eligibility criteria for the Index appear to be inconsistent, such as the requirement that the crypto asset must have traded more than 1% of its free float adjusted market cap on eligible trading venues over the past 30 days, the requirement that it has maintained a unit price greater than one cent for the past consecutive 30 days, and the circumstances in which the Sponsor will retain discretion to exclude one or more crypto assets and or rebalance the weighting of the portfolio assets.
Response to Comment 1
The prospectus has been updated to reconcile the inconsistencies between the publicly available information about the Index and the information incorporated by reference to the 10-K in accordance with the Staff’s comment.
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September 10, 2025
Page 2
Please call me at (312) 845-3724 or my colleague James Audette at (312) 845-3421 if you have any questions or issues you would like to discuss regarding these matters.
Sincerely yours,
Chapman and Cutler llp
Show Raw Text
CORRESP
1
filename1.htm
Richard
Coyle
Partner
Chapman
and Cutler LLP
320 South Canal Street, 27th Floor
Chicago, Illinois 60606
T
312.845.3724
rcoyle@chapman.com
September
10, 2025
Via
EDGAR Correspondence
United
States Securities and Exchange Commission
Division of Corporation Finance
Office of Crypto Assets
100
F Street, N.E.
Washington, D.C. 20549
Re:
Bitwise 10 Crypto Index Fund
File
No. 333-287889
Dear
Ms. Cheng and Ms. Paik:
This
letter responds to your comment provided telephonically on September 3, 2025 regarding amendment no. 2 to the registration statement
filed on Form S-3 for the Bitwise 10 Crypto Index Fund (the “Trust”) with the Staff of the Securities and Exchange
Commission (the “Staff”) on August 25, 2025 (the “Registration Statement”). Capitalized terms used
herein, but not otherwise defined, have the meanings ascribed to them in the Registration Statement.
Comment
1 – General
The
Staff notes the response to prior comment 1 and reissues in part. Please revise to reconcile the inconsistencies between the publicly
available information about the Index and the information incorporated by reference to the 10-K. For example, some of the crypto asset
eligibility criteria for the Index appear to be inconsistent, such as the requirement that the crypto asset must have traded more than
1% of its free float adjusted market cap on eligible trading venues over the past 30 days, the requirement that it has maintained a unit
price greater than one cent for the past consecutive 30 days, and the circumstances in which the Sponsor will retain discretion to exclude
one or more crypto assets and or rebalance the weighting of the portfolio assets.
Response
to Comment 1
The
prospectus has been updated to reconcile the inconsistencies between the publicly available information about the Index and the information
incorporated by reference to the 10-K in accordance with the Staff’s comment.
*
* * * * * * *
September 10, 2025
Page 2
Please
call me at (312) 845-3724 or my colleague James Audette at (312) 845-3421 if you have any questions or issues you would like to
discuss regarding these matters.
Sincerely yours,
Chapman and Cutler llp
By:
/s/
Richard Coyle
Richard
Coyle
cc:
James
Audette, Esq., Chapman and Cutler LLP