SEC Comment Letter for Franklin Solana Trust (SOEZ) — Nov 18, 2025
Franklin Solana Trust
Date: Nov. 18, 2025 · CIK: 0002057388 · Accession: 0000000000-25-010816
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-285121
Letter
November 18, 2025 David Mann President and Chief Executive Officer Franklin Solana Trust c/o Franklin Holdings, LLC One Franklin Parkway San Mateo, CA 94403-1906 Re:Franklin Solana Trust Amendment No. 4 to Registration Statement on Form S-1 Filed September 26, 2025 File No. 333-285121 Dear David Mann: We have reviewed your amended registration statement and have the following comments. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Amendment No. 4 to Registration Statement on Form S-1 General 1.We note your disclosure on the cover page and elsewhere in the prospectus that the Sponsor may seek to use or hold liquid staking tokens in the future. Please confirm your understanding, and revise your disclosure to clarify, that the Fund is not currently permitted to hold liquid staking tokens under the Exchange's generic listing standard. Prospectus Summary Solana Staking Activities, page 4 You state here that the Fund will receive a portion of the Staking Rewards earned through Staking Activities and the remaining portion of the Staking Rewards will be 2.
November 18, 2025 Page 2 retained by the Staking Provider. Please revise to quantify the percentages of the Staking Rewards that will be retained by each of the Fund and the Staking Provider. Please contact Rolf Sundwall at 202-551-3105 or Mark Brunhofer at 202-551-3638 if you have questions regarding comments on the financial statements and related matters. Please contact Irene Paik at 202-551-6553 or Justin Dobbie at 202-551-3469 with any other questions. Sincerely, Division of Corporation Finance Office of Crypto Assets cc:J. Stephen Feinour, Jr.
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November 18, 2025
David Mann
President and Chief Executive Officer
Franklin Solana Trust
c/o Franklin Holdings, LLC
One Franklin Parkway
San Mateo, CA 94403-1906
Re:Franklin Solana Trust
Amendment No. 4 to Registration Statement on Form S-1
Filed September 26, 2025
File No. 333-285121
Dear David Mann:
We have reviewed your amended registration statement and have the following
comments.
Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.
Amendment No. 4 to Registration Statement on Form S-1
General
1.We note your disclosure on the cover page and elsewhere in the prospectus that the
Sponsor may seek to use or hold liquid staking tokens in the future. Please confirm
your understanding, and revise your disclosure to clarify, that the Fund is not
currently permitted to hold liquid staking tokens under the Exchange's generic listing
standard.
Prospectus Summary
Solana Staking Activities, page 4
You state here that the Fund will receive a portion of the Staking Rewards earned
through Staking Activities and the remaining portion of the Staking Rewards will be 2.
November 18, 2025
Page 2
retained by the Staking Provider. Please revise to quantify the percentages of the
Staking Rewards that will be retained by each of the Fund and the Staking Provider.
Please contact Rolf Sundwall at 202-551-3105 or Mark Brunhofer at 202-551-3638 if
you have questions regarding comments on the financial statements and related
matters. Please contact Irene Paik at 202-551-6553 or Justin Dobbie at 202-551-3469 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets
cc:J. Stephen Feinour, Jr.