10-Q: Bitwise Crypto Index Fund Reports Q2 2025 Results
Quarterly Report
Bitwise 10 Crypto Index Fund reported a significant decline in net asset growth and total return for the first half of 2025 compared to the prior year, despite maintaining a high correlation to its benchmark index.
Summary
- Net assets increased to $1,425,390,395 as of June 30, 2025, from $1,365,739,802 at December 31, 2024.
- Net Asset Value (NAV) Per Share rose to $70.42 on June 30, 2025, from $67.47 on December 31, 2024.
- Net increase in net assets from operations for the six months ended June 30, 2025, was $59,650,593, a substantial decrease from $247,806,984 for the same period in 2024.
- Net realized gain from Crypto Assets for the six months ended June 30, 2025, was $12,964,915, up from $1,020,735 in the prior year period.
- Net change in unrealized appreciation from Crypto Assets for the six months ended June 30, 2025, was $63,034,234, significantly lower than $258,794,961 in the prior year period.
- The Trust's total return for the six months ended June 30, 2025, was 4.37%, a sharp decline from 35.33% for the same period in 2024.
- Management fees for the six months ended June 30, 2025, were $16,348,556, an increase from $12,008,661 in the prior year period, driven by higher net asset value.
- As of June 30, 2025, Bitcoin comprised 78.88% of the portfolio, and Ethereum 11.13%, with the remaining 10.18% in other crypto assets.
- The Trust maintained a 99.99% correlation with the Bitwise 10 Large Cap Crypto Index as of June 30, 2025.
- Shares traded at an average discount of 16.43% to NAV from December 9, 2020, to June 30, 2025, with a highest discount of 67.80% on December 28, 2022.
- The Trust closed acceptance of all subscriptions as of November 18, 2021, and has no plans to reopen them.
Sentiment
Score: 4
Explanation: While the Trust effectively tracks its underlying index, its financial performance (net asset increase, unrealized gains, total return) significantly declined compared to the prior year. The persistent discount of share price to NAV and the closed subscription program limit its attractiveness and growth potential, despite some positive regulatory shifts in the broader crypto market. The high management fee also weighs on performance.
Positives
- The Trust achieved a 99.99% correlation to the Bitwise 10 Large Cap Crypto Index as of June 30, 2025, indicating effective tracking of its investment objective.
- Net assets increased to $1.425 billion as of June 30, 2025, from $1.366 billion at December 31, 2024.
- NAV Per Share increased to $70.42 on June 30, 2025, from $67.47 on December 31, 2024.
- Net realized gain from Crypto Assets for the six months ended June 30, 2025, was $12.96 million, a significant increase from $1.02 million in the comparable prior year period.
- The Trust's Crypto Asset Custodian, Coinbase Custody Trust Company, LLC, carries bespoke insurance policies for the crypto assets under custody.
- Management believes it has developed an appropriate proprietary security system to safeguard the Trust's Crypto Assets from theft or attack.
- Recent SEC developments, including the approval of spot Bitcoin and Ethereum ETFs and the formation of a Crypto Task Force, suggest a potential shift towards greater regulatory clarity and explicit rulemaking for digital assets.
- The Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) was signed into law on July 18, 2025, requiring stablecoins to be fully backed, potentially bringing more regulatory certainty to this segment.
Negatives
- Net increase in net assets resulting from operations for the six months ended June 30, 2025, was $59.65 million, significantly lower than $247.81 million for the same period in 2024.
- Net change in unrealized appreciation from Crypto Assets for the six months ended June 30, 2025, was $63.03 million, substantially less than $258.79 million in the prior year period.
- The Trust's total return for the six months ended June 30, 2025, was 4.37%, a considerable drop from 35.33% in the same period of 2024.
- Shares traded at a persistent average discount of 16.43% to NAV from December 9, 2020, to June 30, 2025, with a peak discount of 67.80%, indicating a lack of arbitrage mechanism to maintain NAV parity.
- The Trust has closed new subscriptions since November 18, 2021, limiting new capital inflows and growth opportunities.
- The 2.5% annual management fee is relatively high, impacting overall returns for shareholders.
- The Trust maintains a very small cash balance ($74 as of June 30, 2025), which could limit operational flexibility for non-investment needs.
Risks
- Extreme volatility of trading prices for Crypto Assets, including Bitcoin, could materially adversely affect the value of the Shares.
- The uncertain medium-to-long term value of Shares due to the recent development of Crypto Assets and Blockchain technologies.
- The value of Shares depends on the continued acceptance of Crypto Assets and Blockchain technology, a new and rapidly evolving industry.
- The unregulated nature and lack of transparency surrounding Blockchain technologies and crypto assets may adversely affect portfolio value.
- The limited history of the Bitwise 10 Large Cap Crypto Index.
- Shares may trade at a price significantly above or below the Trust's NAV Per Share due to the absence of an arbitrage mechanism.
- Regulatory changes or actions by U.S. Congress or federal/state agencies could affect the value of Shares or restrict Crypto Asset use, mining, or network operations.
- Changes in SEC policies could adversely impact the value of Shares.
- The Trust or Sponsor could be subject to regulation as a money service business or money transmitter, leading to extraordinary expenses and decreased liquidity.
- Regulatory changes or interpretations could obligate the Trust or Sponsor to register and comply with new regulations, resulting in potentially extraordinary, nonrecurring expenses.
- Potential conflicts of interest may arise among the Sponsor or its affiliates and the Trust.
- The potential discontinuance of the Sponsor's continued services could be detrimental to the Trust.
- The Custodian's possible resignation or removal by the Sponsor.
- Risk of asset loss if Crypto Asset exchanges close due to fraud, failure, or security breaches.
- No assurance that Crypto Assets will maintain their long-term value or that acceptance of Crypto Asset payments will continue to grow.
- Over-the-counter or interdealer markets expose the Trust to counterparty risk due to lack of credit evaluation and regulatory oversight.
- The Trust is not a banking institution and its assets are not subject to FDIC or SIPC protections.
- Inability to identify and mitigate new security threats could lead to theft, loss, or destruction of the Trust's Crypto Assets.
- Risks associated with a Crypto Asset majority control (e.g., 51% attack) could adversely alter the underlying distributed network.
- Dependence on miners or validators for transaction authentication; a shortage could adversely affect fair value or realization of Crypto Assets.
- Geopolitical events, adverse economic developments (rising energy costs, inflation, interest rates), and catastrophic events could negatively affect financial performance.
- Evolving regulatory frameworks may impact the classification and treatment of Portfolio Crypto Assets, leading to compliance challenges and extraordinary expenses.
- Uncertainty regarding the classification of Crypto Assets (security, commodity, virtual currency) by federal and state regulators.
- Increased SEC enforcement actions and investigations in the crypto sector, targeting platforms and services.
- Proposed SEC rules (e.g., dealer definition, custody rule) could negatively affect digital asset trading platforms and asset managers.
- If any Portfolio Crypto Asset is definitively classified as a security, it could have material adverse consequences for its trading, clearing, custody, and general acceptance.
- If the Trust or Sponsor becomes subject to the Investment Company Act or Advisers Act, it may incur extraordinary expenses or face termination.
- The growing scope of the CFTC's regulatory authority and potential overlap with the SEC may create additional uncertainty and compliance costs.
- New laws, regulations, or interpretations detrimental to Crypto Asset platforms could disrupt business operations.
- Political and advocacy activities aimed at influencing the regulatory environment may attract negative public perceptions, harming the Trust's reputation.
Future Outlook
The regulatory landscape for Crypto Assets is complex and continuously evolving, with potential for new laws, regulations, or interpretations that could be detrimental to the Trust. While recent SEC approvals of spot Bitcoin and Ethereum ETFs and legislative efforts like the GENIUS Act suggest a potential shift towards more structured oversight and clarity for major crypto assets, the overall regulatory direction remains uncertain. The Sponsor may choose to terminate the Trust if regulatory changes necessitate fundamental changes to its structure or operations, or if compliance costs become extraordinary.
Management Comments
- The purpose of the Trust is to make it easier for an investor to invest in the Crypto Asset market as a whole without having to pick specific tokens, manage a portfolio, and constantly monitor ongoing news and developments.
- Although the Shares are not the exact equivalent of a direct investment in Crypto Assets, they provide investors with an alternative that constitutes a relatively cost-effective, professionally managed way to participate in Crypto Asset markets.
- The Trust believes that it has met its principal investment objective, evidenced by a 99.99% correlation between the Portfolio Crypto Assets and the assets included in the Index as of June 30, 2025.
- The Trust is aware that the market price of its shares may deviate from the net asset value (NAV) per share, and at times be significantly above or below NAV, but believes this deviation does not affect its principal investment objective.
- Under Regulation M, the Trust, as issuer of the Shares, is not permitted to take any actions that would seek to reconcile the NAV of the Shares and the market price of the Shares.
- As of November 18, 2021, the Sponsor closed the acceptance of all subscriptions to the Bitwise 10 Crypto Index Fund and has no plans to reopen them at this time.
- The Sponsor has evaluated subsequent events through August 7, 2025, and determined there are no material subsequent events requiring disclosure.
Industry Context
The crypto asset industry is experiencing rapid evolution, marked by increasing regulatory scrutiny and legislative efforts in the U.S. The filing highlights the ongoing complexity of classifying crypto assets (security vs. commodity) and the fragmented regulatory oversight by agencies like the SEC and CFTC. Recent approvals of spot Bitcoin and Ethereum ETFs, along with new legislative proposals such as Fit21, CLARITY Act, and the GENIUS Act, signal a move towards establishing a more comprehensive federal framework for digital assets. However, the industry still faces challenges from traditional financial services competitors and the uncertainty of a consistent regulatory approach, which could impact market liquidity and demand for crypto assets.
Comparison to Industry Standards
- The Trust's 99.99% correlation to the Bitwise 10 Large Cap Crypto Index demonstrates strong performance in meeting its passive investment objective, aligning with the high tracking efficiency expected of index-tracking funds.
- The average 16.43% discount of the Trust's shares to NAV, and historical discounts as high as 67.80%, is a significant deviation from the near-NAV trading typically seen in newly approved spot Bitcoin ETFs (e.g., BlackRock's IBIT, Fidelity's FBTC) which benefit from robust arbitrage mechanisms. This structural difference makes the Trust less efficient for price discovery compared to these newer products.
- The 2.5% annual management fee is considerably higher than the fees charged by many recently launched spot crypto ETFs, which typically range from 0.25% to 0.39% (often with initial waivers). This higher fee, combined with the persistent discount to NAV, positions the Trust as a less cost-effective and less liquid investment vehicle for direct crypto exposure compared to its more modern counterparts.
- Unlike spot ETFs that allow for creation and redemption mechanisms to keep market prices aligned with NAV, the Trust's closed subscription and halted withdrawal programs mean it lacks this critical feature, leading to the observed persistent discount, a characteristic common in older, non-redeemable crypto trusts.
Corporate Governance
| Change Type | Description | Effective Date | Impact Assessment |
|---|---|---|---|
| Emerging Growth Company Status | The Trust is an emerging growth company and has elected to take advantage of the extended transition period for complying with new or revised financial accounting standards, resulting in reduced reporting requirements. | N/A | Allows the Trust to comply with certain reduced reporting requirements, potentially lowering compliance costs, but may also mean less frequent or detailed disclosures compared to larger public companies. |
Legal Proceedings
- The SEC instituted proceedings on December 22, 2020, to enjoin Ripple Labs Inc., alleging the offer and sale of XRP was an unregistered, ongoing offering of securities.
- In July 2023, the U.S. District Court for the Southern District of New York found that institutional sales of XRP violated federal securities laws, while programmatic sales on public exchanges did not.
- In August 2024, the court ordered Ripple to pay a $125 million civil penalty.
- The SEC has appealed the court's ruling on programmatic sales, seeking clarity on XRP's regulatory status in secondary market transactions, with the appeal currently pending before the Second Circuit Court of Appeals.
- In a June 2023 action against Coinbase, Inc., the SEC alleged, among other things, that the Portfolio Crypto Assets Solana (SOL) and Cardano (ADA) constituted unregistered securities; this case remains ongoing.
Related Party Transactions
- The Sponsor, Bitwise Investment Advisers, LLC, receives a management fee of 2.5% per annum of the Trust's net asset value, payable monthly in arrears. For the six months ended June 30, 2025, management fees charged were $16,348,556.
- The Sponsor may, at its discretion, waive, reduce, or rebate the Management Fee for any Shareholder or group of Shareholders.
- The Sponsor paid all expenses related to the initial offering, organization, and start-up of the Trust and will not seek reimbursement.
- The Sponsor is responsible for all ordinary operating expenses of the Trust, including administrative, custody, legal, audit, insurance, and other operating expenses.
- Bitwise Index Services, LLC, an affiliate of the Sponsor, administers the Bitwise 10 Large Cap Crypto Index, which the Trust tracks, at no cost to the Trust or the Sponsor.
Stakeholder Impact
- Shareholders experienced a significantly lower net asset increase and total return compared to the prior year, impacting their investment performance.
- Shareholders continue to face a persistent and substantial discount of the Trust's share price to its Net Asset Value (NAV) due to the lack of an ongoing redemption program, limiting their ability to realize full NAV.
- The Sponsor benefits from increased management fees due to the growth in the Trust's net asset value, despite the overall decline in operational performance.
- The Trust's reliance on Coinbase Custody Trust Company, LLC as custodian, which carries bespoke insurance policies, provides a level of security for the crypto assets.
- The evolving and uncertain regulatory environment, including ongoing legal proceedings against crypto entities, creates compliance burdens and potential risks for the Trust and its operations, indirectly affecting all stakeholders.
Next Steps
- The Trust will continue to rebalance its portfolio monthly alongside the Index.
- Management will continue to evaluate the impact of current or anticipated military conflict, terrorism, sanctions, and other geopolitical events, as well as adverse developments in the economy, capital markets, and Blockchain markets.
- The Trust does not expect its assessment related to unrecognized tax benefits to materially change over the next 12 months.
- The SEC case against Ripple Labs Inc. regarding XRP's regulatory status remains ongoing, with an appeal pending before the Second Circuit Court of Appeals.
- The SEC action against Coinbase, Inc., alleging Solana (SOL) and Cardano (ADA) as unregistered securities, remains ongoing.
- Future legislative efforts, such as the CLARITY Act, are awaiting Senate action, and further regulatory guidance is anticipated.
Key Dates
| Date | Description |
|---|---|
| 2017-11-22 | Trust commenced operations. |
| 2018-09-24 | Trust's name changed from Bitwise Hold 10 Private Index Fund, LLC. |
| 2020-05-01 | Trust's name changed from Bitwise 10 Private Index Fund, LLC and converted from a Delaware Limited Liability Company to a Delaware Statutory Trust. |
| 2020-10-07 | Trust halted its withdrawal program in connection with seeking approval for OTCQX quotation. |
| 2020-12-09 | Trust's Shares qualified for public trading on the OTCQX U.S. Marketplace. |
| 2020-12-16 | Highest premium of 649.38% of shares to NAV recorded. |
| 2020-12-22 | SEC instituted proceedings to enjoin Ripple Labs Inc. regarding XRP. |
| 2020-12-23 | Trust liquidated its position in XRP based on SEC's complaint. |
| 2021-08-04 | Lowest premium of 0.27% of shares to NAV recorded. |
| 2021-08-31 | Sponsor developed process for identifying a principal market for valuation. |
| 2021-09-24 | Lowest discount of 0.09% of shares to NAV recorded. |
| 2021-11-18 | Sponsor closed the acceptance of all subscriptions to the Bitwise 10 Crypto Index Fund. |
| 2022-12-28 | Highest discount of 67.80% of shares to NAV recorded. |
| 2023-02-13 | Sponsor adapted principal market valuation process using third-party vendor Lukka, Inc. |
| 2023-06-01 | SEC alleged Solana (SOL) and Cardano (ADA) constituted unregistered securities in an action against Coinbase, Inc. |
| 2023-07-01 | U.S. District Court for the Southern District of New York found institutional sales of XRP violated federal securities laws. |
| 2024-01-01 | SEC approved multiple spot Bitcoin ETFs. |
| 2024-05-22 | U.S. House of Representatives passed the Financial Innovation and Technology for the 21st Century Act (Fit21). |
| 2024-07-01 | SEC approved multiple spot Ethereum ETFs. |
| 2024-08-01 | Court ordered Ripple to pay a $125 million civil penalty. |
| 2024-12-31 | Fiscal year ended. |
| 2025-01-23 | President Trump issued Executive Order 14178, 'Strengthening American Leadership in Digital Financial Technology'. |
| 2025-04-01 | SEC Crypto Task Force held a series of public roundtables (through June 2025). |
| 2025-06-23 | House passed the Digital Asset Market Structure and Investor Protection Act (CLARITY Act). |
| 2025-06-30 | End of the quarterly period covered by this report. |
| 2025-07-18 | Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) signed into law by President Trump. |
| 2025-08-07 | Date financial statements were available to be issued and report filing date. |
Recommendation
holdThe Trust effectively tracks its underlying index, which is a positive for investors seeking broad crypto exposure. However, the significant underperformance in net asset growth and total return compared to the prior year, coupled with the persistent and substantial discount of the share price to NAV, makes it less attractive for new investment. The high management fee further erodes returns. While recent regulatory clarity (spot ETFs) is positive for the broader crypto market, this specific trust's structure (closed subscriptions, no redemption mechanism) limits its ability to capitalize on these developments by closing the NAV discount. Existing holders might hold due to potential future market appreciation of crypto assets, but new capital would likely seek more efficient investment vehicles like spot ETFs.
Keywords
Crypto Index Fund, Bitcoin, Ethereum, Crypto Assets, Digital Assets, SEC Filing, 10-Q, Investment Fund, Blockchain, Regulatory Risk, Asset Management, BITW, OTC Markets, Net Asset Value, Portfolio Performance
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