SEC Comment Letter for Bitwise Solana Staking ETF (BSOL) — Dec 4, 2024
Bitwise Solana Staking ETF
Date: Dec. 4, 2024 · CIK: 0002045872 · Accession: 0000000000-24-013365
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-283391
Letter
December 4, 2024 Hunter Horsley President Bitwise Solana ETF c/o Bitwise Investment Advisers, LLC 250 Montgomery Street, Suite 200 San Francisco, CA 94104 Re:Bitwise Solana ETF Registration Statement on Form S-1 Filed November 21, 2024 File No. 333-283391 Dear Hunter Horsley: 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.
December 4, 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 Sonia Bednarowski at 202-551-3666 or Sandra Hunter Berkheimer at 202-551-3758 with any questions. Sincerely, Division of Corporation Finance Office of Crypto Assets
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December 4, 2024
Hunter Horsley
President
Bitwise Solana ETF
c/o Bitwise Investment Advisers, LLC
250 Montgomery Street, Suite 200
San Francisco, CA 94104
Re:Bitwise Solana ETF
Registration Statement on Form S-1
Filed November 21, 2024
File No. 333-283391
Dear Hunter Horsley:
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.
December 4, 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 Sonia Bednarowski at 202-551-3666 or Sandra Hunter Berkheimer at
202-551-3758 with any questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets