SEC Comment Letter for Canary Marinade Solana ETF (SOLC) (CIK 0002041869) (SOLC) — Nov 8, 2024
Canary Marinade Solana ETF (SOLC) (CIK 0002041869)
Date: Nov. 8, 2024 · CIK: 0002041869 · Accession: 0000000000-24-012493
AI Filing Summary & Sentiment
File numbers found in text: 333-282903
Letter
November 8, 2024 Steven McClurg Chief Executive Officer Canary Solana ETF 1131 4th Avenue S #230 Nashville, TN 37210 Re:Canary Solana ETF Registration Statement on Form S-1 Filed October 30, 2024 FIle No. 333-282903 Dear Steven McClurg: 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 provide exposure to the price of Solana and that you will meet the objective by holding Solana. The Commission has stated that Solana is offered and sold as 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.
November 8, 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:Morrison C. Warren
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November 8, 2024
Steven McClurg
Chief Executive Officer
Canary Solana ETF
1131 4th Avenue S #230
Nashville, TN 37210
Re:Canary Solana ETF
Registration Statement on Form S-1
Filed October 30, 2024
FIle No. 333-282903
Dear Steven McClurg:
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 provide exposure to the price
of Solana and that you will meet the objective by holding Solana. The Commission
has stated that Solana is offered and sold as 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.
November 8, 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:Morrison C. Warren