SEC Comment Letter for 21Shares Solana Staking ETF (TSOL) — Jul 17, 2024
21Shares Solana Staking ETF
Date: July 17, 2024 · CIK: 0002028834 · Accession: 0000000000-24-008122
AI Filing Summary & Sentiment
File numbers found in text: 333-280557
Letter
July 17, 2024 Ophelia Snyder President 21Shares Core Solana ETF 477 Madison Avenue, 6th Floor New York, New York 10022 Re:21Shares Core Solana ETF Registration Statement on Form S-1 Filed June 28, 2024 File No. 333-280557 Dear Ophelia Snyder: We have reviewed your registration statement and have the following comment. Registration Statement on Form S-1 General 1.You state that the investment objective of the Trust is to reflect the performance of the price of Solana and that you will meet the objective by holding Solana. The Commission has stated that Solana meets the definition of a security under the federal securities laws. In that regard, we refer you to the complaints filed by the Commission against Binance Holdings Limited, BAM Trading Services Inc., BAM Management US Holdings Inc. and Changpeng Zhao, Coinbase, Inc. and Coinbase Global, Inc., and Payward, Inc. and Payward Ventures, Inc. Therefore, the Trust appears to meet the definition of an investment company under the Investment Company Act of 1940. Please file a request for withdrawal of the registration statement.
July 17, 2024 Page 2 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. Please contact Austin Stanton at 202-551-2197 or Sandra Hunter Berkheimer at 202-551- 3758 with any questions. Sincerely, Division of Corporation Finance Office of Crypto Assets cc:Allison M. Fumai
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July 17, 2024
Ophelia Snyder
President
21Shares Core Solana ETF
477 Madison Avenue, 6th Floor
New York, New York 10022
Re:21Shares Core Solana ETF
Registration Statement on Form S-1
Filed June 28, 2024
File No. 333-280557
Dear Ophelia Snyder:
We have reviewed your registration statement and have the following comment.
Registration Statement on Form S-1
General
1.You state that the investment objective of the Trust is to reflect the performance of the
price of Solana and that you will meet the objective by holding Solana. The Commission
has stated that Solana meets the definition of a security under the federal securities laws.
In that regard, we refer you to the complaints filed by the Commission against Binance
Holdings Limited, BAM Trading Services Inc., BAM Management US Holdings Inc. and
Changpeng Zhao, Coinbase, Inc. and Coinbase Global, Inc., and Payward, Inc. and
Payward Ventures, Inc. Therefore, the Trust appears to meet the definition of an
investment company under the Investment Company Act of 1940. Please file a request for
withdrawal of the registration statement.
July 17, 2024
Page 2
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.
Please contact Austin Stanton at 202-551-2197 or Sandra Hunter Berkheimer at 202-551-
3758 with any questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets
cc:Allison M. Fumai