SecProbe.io

August 15, 2025
Cynthia Lo Bessette
President
Fidelity Solana Fund
c/o FD Funds Management LLC
245 Summer Stree V13E
Boston, MA 02210
Re:Fidelity Solana Fund
Amendment No. 1 to Registration Statement on Form S-1
Filed July 31, 2025
File No. 333-288046
Dear Cynthia Lo Bessette:
            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. Unless we note
otherwise, any references to prior comments are to comments in our July 3, 2025 letter.
Amendment No. 1 to Registration Statement on Form S-1
Prospectus Summary
SOL Staking Activities, page 3
1.We note your response to prior comment 5 that under normal circumstances, the
Sponsor will seek to stake  all of the Trust's SOL except for SOL reserved by the
Sponsor in its sole discretion to facilitate foreseeable redemption transactions, pay
Trust expenses or otherwise protect the Trust and its assets. We also note your
disclosure elsewhere that the Sponsor will seek to stake a portion of the Trust's SOL.
Please revise your disclosure for consistency. Please also revise to quantify the
percentage of the Trust's SOL that will be staked, or confirm that you intend to do so
in a pre-effective amendment.

August 15, 2025
Page 2
Risk Factors
Risk Factors Related to Digital Assets, page 22
2.Please discuss, if known, the reasons for the periods of extreme volatility of SOL, and
describe any unique features of SOL that may make it more susceptible to extreme
volatility or otherwise not correlate to trends in the broader crypto asset markets.
The Trust's Staking Program
Allocation of Staking Rewards, page 75
3.We note your revised disclosure in response to prior comment 17. Please revise your
disclosure here and in the Use of Proceeds section to clarify whether the Trust will
stake the staking rewards retained.
Liquidity Risk Management, page 76
4.Please revise to provide a complete description of your liquidity risk policies and
procedures. To the extent such policies and procedures are intended to be consistent
with the exchange's proposed generic listing standards, please revise accordingly.
Node Operators, page 76
5.We note your disclosure that the Sponsor will utilize the services of the Custodian to
stake, or cause to be staked, a portion of the Trust's SOL with one or more trusted
Node Operators.  Please confirm that, once known, you will identify the Node
Operator(s).  In addition, to the extent the Trust engages additional Node
Operators, discuss the factors that will be used to determine how much SOL to
allocate among multiple Node Operators.
            Please contact Kate Tillan at 202-551-3604 or Robert Telewicz at 202-551-3438 if
you have questions regarding comments on the financial statements and related
matters. Please contact Irene Paik at 202-551-6553 or Sandra Hunter Berkheimer at 202-551-
3758 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets
cc:Morrison C. Warren, Esq.,