XRP.NYSE ARCABitwise Xrp Etf

10-K: Bitwise XRP ETF Reports Initial Operations, Faces XRP Volatility

Sentiment:

Annual Report


Bitwise XRP ETF details its inaugural operational period, reporting a net decrease in assets due to XRP price depreciation and outlining significant risks inherent in digital asset investments.

Capital raiseThe Trust sold 18,090,000 Shares for aggregate proceeds of $390,263,381 from November 20, 2025, through March 12, 2026, to make investments in XRP.Bitwise Investment Manager, LLC (BIM), an affiliate of the Sponsor, purchased the initial 100,000 Shares (Seed Baskets) for $2,277,445 on November 19, 2025.
Worse than expectedNet investment loss of $25,000 for the period from November 19, 2025, to December 31, 2025.Net change in unrealized depreciation on investment in XRP of $25,912,000.Principal Market NAV per-share decreased by 10.14% during the initial operational period.The XRPUSD_NY price depreciated from $2.03 per XRP on November 19, 2025, to $1.82 per XRP on December 31, 2025.

Summary

  • The Bitwise XRP ETF commenced operations on November 19, 2025, with the objective to provide exposure to the value of XRP held by the Trust, less operational expenses.
  • As of December 31, 2025, the Trust held 131,223,200.0749 XRP with a total market value of $239,758,000 (Principal Market NAV).
  • The Trust reported a net investment loss of $25,000 and a net change in unrealized depreciation on investment in XRP of $25,912,000 for the period from November 19, 2025, to December 31, 2025.
  • The Principal Market NAV per-share decreased by 10.14% during this initial operational period, primarily due to the XRPUSD_NY price depreciating from $2.03 per XRP on November 19, 2025, to $1.82 per XRP on December 31, 2025.
  • The Sponsor Fee is 0.34% per annum of the Trust's XRP holdings, but it was waived on the first $500 million of Trust assets from November 20, 2025, through December 19, 2025.
  • The Trust is passively managed, meaning the Sponsor does not actively trade XRP to capitalize on price movements or use hedging techniques.
  • The Trust uses the CME CF XRP Dollar Reference Rate New York Variant (Pricing Benchmark) to value its net assets and Shares daily.
  • Coinbase Custody Trust Company, LLC serves as the XRP Custodian, utilizing multi-layer cold storage security.
  • From November 20, 2025, through March 12, 2026, the Trust sold 18,090,000 Shares for aggregate proceeds of $390,263,381.
  • The filing highlights significant risks associated with digital assets, including extreme price volatility, regulatory uncertainty, potential for market manipulation, and operational vulnerabilities of the XRP Ledger and trading platforms.

Sentiment

Score: 4

Explanation: StockSavvy.ai views this as a challenging start for the Bitwise XRP ETF, with initial financial performance negatively impacted by XRP price depreciation. The comprehensive disclosure of risks, while transparent, highlights the speculative nature of the underlying asset and the Trust's passive management strategy.

Positives

  • The Sponsor waived the entire 0.34% annual fee on the first $500 million of Trust assets for one month (November 20 December 19, 2025), reducing initial costs for investors.
  • The Trust provides investors with access to the XRP market through a traditional brokerage account, bypassing the complexities and risks of direct XRP acquisition and custody.
  • The Trust avoids derivatives, which limits additional counterparty and credit risks.
  • Coinbase Custody, the XRP Custodian, has a long track record in digital asset custody and employs robust multi-layer cold storage security measures.
  • The XRP Ledger is designed for transactional utility, offering high speed (up to 1,500 transactions per second), energy efficiency, and very low transaction fees (typically a fraction of a cent).
  • The SEC dismissed lawsuits against major digital asset trading platforms (Coinbase, Kraken, Binance) in early 2025, reducing immediate regulatory uncertainty for key industry participants.
  • The Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (GENIUS Act) established a federal framework for payment stablecoins, requiring full backing and regulatory oversight, which could contribute to broader market stability.
  • The Digital Asset Market Clarity Act of 2025 (CLARITY Act), passed by the House, aims to provide a clear regulatory framework for digital assets, delineating SEC/CFTC jurisdiction and criteria for commodity vs. security classification, which could foster innovation and certainty.

Negatives

  • The Trust experienced a net investment loss of $25,000 for its initial operational period from November 19 to December 31, 2025.
  • A significant net change in unrealized depreciation on investment in XRP of $25,912,000 was recorded during the period.
  • The Principal Market NAV per-share decreased by 10.14% from November 19, 2025, to December 31, 2025, primarily due to XRP price depreciation from $2.03 to $1.82.
  • The amount of XRP represented by each Share will continuously decline over the Trust's life due to the Sponsor Fee and other expenses, irrespective of XRP's trading price.
  • The Trust is passively managed and will not employ strategies to mitigate losses from XRP price decreases or capitalize on price increases, leaving investors fully exposed to market volatility.
  • XRP has exhibited extreme historical annualized volatility of 100.14% and a maximum annual price decrease of 78.81%, indicating high investment risk.
  • The XRP Ledger's reliance on a relatively small number of validators (35 in the default list as of October 2025) could make it more vulnerable to manipulation if a malicious actor gains control of over 80% of trusted validators.
  • XRP Ledger validators are not directly compensated, raising concerns about the long-term sustainability of their participation and the network's security.
  • The fixed supply of 100 billion XRP tokens, created at launch, combined with token burning for transaction fees, could lead to deflationary pressure and potential liquidity issues in the distant future, and may not scale well with rapidly expanding use cases.
  • Significant XRP holdings by Ripple Labs and early stakeholders (20 billion by founders, 80 billion initially to Ripple Labs) raise concerns about centralization and potential market impact from large sales.
  • The Trust will not participate in any staking programs, meaning Shareholders will not receive staking rewards or other income that might be available through direct XRP ownership.
  • The Trust explicitly disclaims all Incidental Rights and IR Assets (e.g., from forks or airdrops), causing Shareholders to forgo potential economic benefits from such events.
  • The XRP Custodian's liability to the Trust is limited, and its insurance coverage is shared among all Coinbase customers, potentially being insufficient to cover significant losses.
  • Assets held in the Trading Balance with the Prime Execution Agent are held on an omnibus basis, increasing the risk of loss in the event of the Prime Execution Agent's insolvency.
  • As a new fund, there is no guarantee the Trust will achieve or maintain an economically viable size, which could lead to its termination at a disadvantageous time for Shareholders.
  • The Sponsor is leanly staffed and relies heavily on key personnel, posing a risk if these individuals leave or are unable to perform their duties.
  • Cash creations and redemptions introduce drawbacks such as potential slippage (paying a higher price for XRP than the NAV valuation) and reduced tax efficiency.
  • Potential conflicts of interest may arise between the Sponsor or its affiliates and the Trust, as the Sponsor is allowed to consider its own interests.
  • Shareholders lack the regulatory protections afforded to investors in registered investment companies or commodity pools.
  • The Trust is subject to market risk, including the potential loss of the entire principal investment.
  • The Trust's reliance on Trade Credits for cash creations/redemptions means that if credits are unavailable or exhausted, delays in XRP transactions or liquidation of Trust assets by the Trade Credit Lender could occur.
  • Loss of critical banking relationships or failure of banks used by the Prime Execution Agent could disrupt Trust operations or cause losses, especially for uninsured balances.

Risks

  • A determination that XRP or any other digital asset is offered or sold as a security may adversely affect the price of XRP and the value of the Shares, and result in potentially extraordinary, nonrecurring expenses to, or termination of, the Trust.
  • The trading prices of many digital assets, including XRP, have experienced extreme volatility in recent periods and may continue to do so. Extreme volatility in the future, including further declines in the trading price of XRP, could have a material adverse effect on the value of the Shares and the Shares could lose all or substantially all of their value.
  • Digital assets, including XRP, are subject to a number of risks related to the digital asset ecosystem, including market conditions, trading activity on unregulated platforms, adoption rates, manipulative trading, governmental actions, and competition.
  • The price of the Shares of the Trust is represented by the Pricing Benchmark that may also be subject to momentum pricing due to speculation regarding future appreciation in value of XRP, leading to greater volatility that could adversely affect the value of the Shares.
  • A decline in the popularity or acceptance of the XRP Ledger, or the value of XRP, would harm the value of the Trust.
  • Many digital assets, including XRP, were only introduced within the past decade, and the medium-to-long-term value of the Shares is subject to a number of factors relating to the capabilities and development of blockchain technologies and to the fundamental investment characteristics of digital assets.
  • Recent developments in the digital asset economy have led to extreme volatility and disruption in digital asset markets, a loss of confidence in participants of the digital asset ecosystem, significant negative publicity surrounding digital assets broadly and market-wide declines in liquidity.
  • Blockchains utilizing consensus-based algorithms, such as the XRP Ledger, are a relatively recent innovation, and have not been subject to as widespread use or adoption over as long of a period of time as traditional proof-of-work blockchains.
  • The value of the Shares relates directly to the price of XRP, which may be highly volatile and subject to fluctuations due to a number of factors.
  • XRP is a relatively new technological innovation with a limited operating history.
  • Mathematical or technological advances could undermine the XRP Ledgers consensus mechanism.
  • A decline in the adoption of XRP or the XRP Ledger could negatively impact the Trust.
  • The fixed supply of XRP may negatively impact the operation of the XRP Ledger.
  • The significant holdings of XRP by Ripple Labs and other early stakeholders could have an adverse effect on the market price of XRP.
  • Competition from other consortia or private blockchains could have a negative impact on the price of XRP and adversely affect an investment in the Shares.
  • Any name change and any associated rebranding initiative may not be favorably received by the digital asset community, which could negatively impact the price of XRP and the value of the Shares.
  • The Trust will not directly or indirectly participate in any staking program, and accordingly the Shareholders will not receive any staking rewards or other income.
  • The loss or destruction of a private key required to access XRP may be irreversible.
  • New competing digital assets may result in a reduction in demand for XRP, which could have a negative impact on the price of XRP and may have a negative impact on the performance of the Trust.
  • Competition from central bank digital currencies (CBDCs) and emerging payments initiatives involving financial institutions could adversely affect the price of XRP and other digital assets.
  • The price of XRP may be affected due to stablecoins (including Tether and USDC), the activities of stablecoin issuers and their regulatory treatment.
  • Validators may cease participating in validating activities because they are provided no direct financial incentive to participate or because certain jurisdictions may limit or otherwise regulate validating activities, which could negatively impact the price of XRP and the value of the Shares.
  • Anonymity and illicit financing risk.
  • A temporary or permanent fork of the XRP Ledger could adversely affect the value of the Shares.
  • If a malicious actor obtains control of more than 80% of the validating nodes on the XRP Ledger, or otherwise obtains control over the XRP Ledger through its influence over trusted validators or otherwise, such actor could manipulate the XRP Ledger, which could adversely affect the value of the Shares or the ability of the Trust to operate.
  • The digital asset trading platforms on which XRP trades are relatively new and largely unregulated or may not be complying with existing regulations.
  • Digital asset trading platforms may be exposed to security breaches.
  • Digital asset trading platforms may be exposed to fraud and market manipulation.
  • Digital asset trading platforms may be exposed to wash trading.
  • Digital asset trading platforms may be exposed to front-running.
  • Momentum pricing.
  • Political or economic crises may motivate large-scale sales of XRP, which could result in a reduction in the price of XRP and adversely affect an investment in the Shares.
  • Ownership of XRP is pseudonymous, and the supply of accessible XRP is unknown. Entities with substantial holdings in XRP may engage in large-scale sales or distributions, either on nonmarket terms or in the ordinary course, which could result in a reduction in the price of XRP and adversely affect an investment in the Shares.
  • Irrevocable nature of blockchain-recorded transactions.
  • A disruption of the internet may affect XRP Ledger operations, which may adversely affect the XRP industry and an investment in the Trust.
  • Potential amendments to the XRP Ledgers protocols and software could, if accepted and authorized by the XRP Ledger community, adversely affect an investment in the Trust.
  • Decentralized governance of the XRP Ledger could have a negative impact on the performance of the Trust.
  • Double-spending risks.
  • Flaws in source code.
  • Competition from the emergence or growth of other digital assets or methods of investing in XRP could have a negative impact on the price of XRP and adversely affect the value of the Shares.
  • The Pricing Benchmark, XRR and CME XRP Real Time Price each have a limited history.
  • The Benchmark Provider has substantial discretion at any time to change the methodology used to calculate the Pricing Benchmark, including the Constituent Platforms that contribute prices to the Trusts NAV.
  • The Pricing Benchmark could fail to track the global XRP price, and a failure of the Pricing Benchmark could adversely affect the value of the Shares.
  • The Sponsor can discontinue using the Pricing Benchmark and use a different pricing or valuation methodology instead.
  • The Pricing Benchmark price used to calculate the value of the Trusts XRP may be volatile, adversely affecting the value of the Shares.
  • The Pricing Benchmark price being used to determine the NAV of the Trust may not be consistent with GAAP.
  • Investing in XRP and, consequently, the Trust, is speculative. The price of XRP is volatile, and market movements of XRP are difficult to predict.
  • The Trust is subject to market risk.
  • Different from directly owning XRP.
  • The Trust is a passive investment vehicle.
  • The value of the Shares may be influenced by a variety of factors unrelated to the price of XRP.
  • Liquidity risk.
  • The NAV may not always correspond to the market price of XRP and, as a result, Baskets may be created or redeemed at a value that is different from the market price of the Shares.
  • The Shares may trade at a discount or premium in the trading price relative to the NAV as a result of non-concurrent trading hours between the Exchange and digital asset trading platforms.
  • Buying and selling activity associated with the creation and redemption of Baskets may adversely affect an investment in the Shares.
  • The inability of Authorized Participants and market makers to hedge their XRP exposure may adversely affect the liquidity of Shares and the value of an investment in the Shares.
  • Arbitrage transactions intended to keep the price of Shares closely linked to the price of XRP may be problematic if the process for the creation and redemption of Baskets encounters difficulties, which may adversely affect an investment in the Shares.
  • Investors may be adversely affected by Creation Orders or Redemption Orders that are subject to postponement, suspension or rejection under certain circumstances.
  • Investors may be adversely affected by an overstatement or understatement of the NAV calculation of the Trust due to the valuation method employed on the date of the NAV calculation.
  • As an owner of Shares, you will not have the rights normally associated with ownership of other types of shares.
  • The Sponsor and the Trustee may agree to amend the Trust Agreement or Sponsor Agreement without the consent of the Shareholders.
  • The Trust is subject to risks due to its concentration of investments in a single asset class.
  • A possible short squeeze due to a sudden increase in demand for the Shares that largely exceeds supply may lead to price volatility in the Shares.
  • As the Sponsor and its management have a limited history of operating an investment vehicle like the Trust, their experience may be inadequate or unsuitable to manage the Trust.
  • Security threats and cyber-attacks could result in the halting of Trust operations and a loss of Trust assets or damage to the reputation of the Trust, each of which could result in a reduction in the price of the Shares.
  • Service providers may have limited indemnification obligations to the Trust, which could be negatively impacted as a result.
  • The Trusts risk management processes and policies may prove to not be adequate to prevent any loss of the Trusts XRP.
  • The development and commercialization of the Trust is subject to competitive pressures.
  • The lack of active trading markets for the Shares may result in losses on investors investments at the time of disposition of Shares.
  • The Trust may be required to terminate and liquidate at a time that is disadvantageous to Shareholders.
  • The Exchange on which the Shares are listed may halt trading in the Shares, which would adversely impact an investors ability to sell Shares.
  • The liquidity of the Shares may also be affected by the withdrawal from participation of Authorized Participants, which could adversely affect the market price of the Shares.
  • The market infrastructure of the XRP spot market could result in the absence of active Authorized Participants able to support the trading activity of the Trust.
  • Digital asset trading platforms are not subject to the same regulatory oversight as traditional equity exchanges, which could negatively impact the ability of Authorized Participants to implement arbitrage mechanisms.
  • The Authorized Participants serve in such capacity for several competing exchange-traded XRP products, which could adversely affect the market for the Shares.
  • Shareholders that are not Authorized Participants may only purchase or sell their Shares in secondary trading markets, and the conditions associated with trading in secondary markets may adversely affect investors investment in the Shares.
  • The Sponsor is leanly staffed and relies heavily on key personnel to manage its activities.
  • Conducting creations and redemptions for cash has drawbacks.
  • Potential conflicts of interest may arise among the Sponsor or its affiliates and the Trust.
  • The Trust is new, and if it is not profitable, the Trust may terminate and liquidate at a time that is disadvantageous to Shareholders.
  • The Sponsor may discontinue its services, which may be detrimental to the Trust.
  • Any of the service providers could resign or be removed by the Trust, which could trigger early termination of the Trust.
  • The lack of independent advisers representing investors in the Trust may cause Shareholders to be adversely affected.
  • The liability of the Sponsor and the Trustee is limited, and the value of the Shares will be adversely affected if the Trust is required to indemnify the Trustee or the Sponsor.
  • Shareholders limited rights of legal recourse against the Trust, Sponsor, Administrator, Transfer Agent, Cash Custodian, Prime Execution Agent and XRP Custodian and the Trusts lack of direct insurance protection expose the Trust and its Shareholders to the risk of loss of the Trusts XRP for which no person is liable.
  • During the rare and limited circumstances when the Trust utilizes the Agent Execution Model pursuant to a Cash Creation Order, it may utilize Trade Credits. If the Trade Credits are not available or become exhausted, the Trust may face delays in buying or selling XRP that may adversely impact Shareholders; if the Trust does not repay the Trade Credits on time, its assets may be liquidated by the Trade Credit Lender and its affiliates.
  • Loss of a critical banking relationship for, or the failure of a bank used by, the Prime Execution Agent could adversely impact the Trusts ability to create or redeem Baskets, or could cause losses to the Trust, in the limited circumstances when the Trust utilizes the Agent Execution Model.
  • The Prime Execution Agent routes orders through Connected Trading Venues in connection with trading services under the Prime Execution Agreement. The loss or failure of any such Connected Trading Venues may adversely affect the Prime Execution Agents business and cause losses for the Trust.
  • A loss of confidence or breach of the XRP Custodian may adversely affect the Trust and the value of an investment in the Shares.
  • The Trust is dependent on the XRP Custodian, which is Coinbase Custody, and to a lesser extent, the Prime Execution Agent, Coinbase Inc. to operate.
  • The XRP Custodian could become insolvent.
  • XRP held by the Trust is not subject to FDIC or SIPC protections.
  • Third parties may infringe upon or otherwise violate intellectual property rights or assert that the Sponsor has infringed or otherwise violated their intellectual property rights, which may result in significant costs and diverted attention.
  • Due to the increased use of technologies, intentional and unintentional cyber-attacks pose operational and information security risks.
  • The Trust faces risks related to the outbreak of infectious diseases or other public health issues, which could negatively impact the value of the Trusts holdings and significantly disrupt its operations.
  • The ongoing activities of the Trust may generate tax liabilities for Shareholders.
  • The IRS may disagree with or seek to challenge the Trusts treatment as a grantor trust.
  • The tax treatment of XRP and transactions involving XRP for U.S. federal income tax purposes may change.
  • The tax treatment of XRP and transactions involving XRP for state and local tax purposes is not settled.
  • A fork of the XRP Ledger or an airdrop could result in Shareholders incurring a tax liability.
  • The intended tax treatment of the Trust will limit the flexibility of the Trusts investment decisions.
  • WHFIT reporting risks.
  • As a new fund, there is no guarantee that an active trading market for the Shares will develop.
  • The Trust may be required to terminate and liquidate at a time that is disadvantageous to Shareholders.

Future Outlook

The Trust is passively managed and will not actively manage XRP holdings or use hedging techniques. The Sponsor may change the pricing benchmark with prior notice if investment conditions change or the current benchmark does not accurately reflect XRP's global market price. The regulatory landscape for digital assets is evolving, with new federal frameworks (CLARITY Act, GENIUS Act) and potential future rulemaking by regulators, which could impact the Trust's operations and the value of XRP.

Management Comments

  • The Sponsor believes that the design of the Trust will enable certain investors to more effectively and efficiently implement strategic and tactical asset allocation strategies that use XRP by investing in the Shares rather than purchasing, holding and trading XRP directly.
  • The Sponsor believes that the XRP Custodians policies, procedures, and controls for safekeeping, exclusively possessing, and controlling the Trusts XRP holdings are consistent with industry best practices to protect against theft, loss, and unauthorized and accidental use of the private keys.
  • The Sponsor believes that the security procedures in place for the Trust, including, but not limited to, offline storage, or cold storage, multiple encrypted private key shards, and other measures, are reasonably designed to safeguard the Trusts XRP.
  • The Sponsor does not anticipate that the need to fair value XRP will be a common occurrence.
  • The Principal Executive Officer and the Principal Financial and Accounting Officer of the Sponsor concluded that, as of December 31, 2025, the Trusts disclosure controls and procedures were effective.

Industry Context

StockSavvy.ai notes that the launch of the Bitwise XRP ETF comes amidst a rapidly evolving regulatory environment for digital assets in the U.S., marked by significant legislative efforts like the GENIUS Act for stablecoins and the proposed CLARITY Act for broader digital asset classification. The dismissal of SEC lawsuits against major platforms like Coinbase and Binance in early 2025 has reduced some immediate regulatory pressures, potentially fostering a more stable environment for crypto-related financial products. However, the inherent volatility of XRP and the nascent stage of the digital asset industry continue to pose substantial risks, distinguishing it from traditional asset classes.

Comparison to Industry Standards

  • The Trust's 0.34% Sponsor Fee is competitive within the emerging crypto ETF market, especially with the initial waiver on the first $500 million of assets, aiming to attract initial capital similar to strategies seen in other newly launched digital asset ETFs.
  • XRP's historical annualized volatility of 100.14% and maximum annual price decrease of 78.81% significantly exceed the volatility of traditional financial assets and even other major cryptocurrencies like Bitcoin (which, while volatile, has a longer track record).
  • The XRP Ledger's transaction speed (1,500 transactions per second) and low fees are superior to Bitcoin and Ethereum networks, aligning with its stated purpose as a global real-time payment system, potentially offering a competitive advantage for specific use cases.
  • The reliance on a relatively small number of validators (35 in the default UNL as of October 2025, with Ripple Labs running only 1) contrasts with the more distributed validation mechanisms of larger proof-of-work or proof-of-stake networks, which could be perceived as a governance and security vulnerability compared to more decentralized models.

Management Changes

RolePrevious PersonNew PersonEffective DateReason
Vice PresidentNAJames Bebrin IIINovember 2025Appointment
Vice PresidentNAPhuong BlackNovember 2025Appointment
Vice President, General Counsel and Head of Compliance, U.S. Asset ManagementNAJohanna Collins-WoodNovember 2025Appointment

Corporate Governance

Change TypeDescriptionEffective DateImpact Assessment
Policy AdoptionAdoption of a Recovery Policy for Erroneously Awarded Incentive-Based Compensation, establishing a framework for potential recovery of incentive-based compensation in case of accounting restatements.January 4, 2024Enhances corporate accountability and investor protection by outlining procedures for clawbacks, aligning with NYSE Rule 5.3-E(p).
Policy AdoptionAdoption of an Insider Trading Policy that applies to the Sponsor's directors, officers, and employees, governing the purchase and sale of certain investment products.NAAims to promote compliance with insider trading laws and prevent conflicts of interest, requiring pre-clearance for significant XRP-related transactions.

Legal Proceedings

  • SEC v. Ripple Labs: Concluded in August 2025, with S.D.N.Y. finding XRP not inherently a security, but direct institutional sales were unregistered securities. Ripple Labs paid a $125 million civil penalty.
  • SEC v. Binance Holdings Ltd., et al, SEC v. Coinbase, Inc., and Coinbase Global, Inc., SEC v. Kraken: SEC brought suits in June 2023 (Binance, Coinbase) and November 2023 (Kraken) alleging operation of unregistered securities exchanges. Dismissed with prejudice in February, March, and May 2025, respectively.

Related Party Transactions

  • Bitwise Asset Management, Inc. (BAM), the parent company of the Sponsor, purchased 8 Seed Shares for $200.00 on October 10, 2025, and redeemed them on November 19, 2025.
  • Bitwise Investment Manager, LLC (BIM), an affiliate of the Sponsor, purchased the initial 100,000 Shares (Seed Baskets) for $2,277,445 on November 19, 2025.
  • The Trust pays a unitary Sponsor Fee of 0.34% per annum to Bitwise Investment Advisers, LLC (the Sponsor), which is a related party.
  • The Sponsor has agreed to assume and pay normal operating expenses of the Trust in exchange for the Sponsor Fee.
  • Coinbase, Inc. (Prime Execution Agent) is an affiliate of Coinbase Custody Trust Company, LLC (XRP Custodian).
  • Coinbase Credit, Inc. (Trade Credit Lender) is an affiliate of the Prime Execution Agent and XRP Custodian, providing short-term trade credit to the Trust.
  • An affiliate of the Sponsor has a minority equity interest in the issuer of USDC, a stablecoin whose market dynamics can affect XRP.

Stakeholder Impact

  • Shareholders experienced a 10.14% decrease in Principal Market NAV per share during the initial operating period, primarily due to XRP price depreciation. They face risks from XRP price volatility, passive management, limited legal recourse, and potential tax liabilities without corresponding distributions. They also forgo potential economic benefits from forks or airdrops.
  • The Sponsor (Bitwise Investment Advisers, LLC) receives a 0.34% annual Sponsor Fee (with an initial waiver), which covers most operating expenses. The Sponsor manages the Trust and its service providers, but also faces competition from other XRP products.
  • Authorized Participants engage in the creation and redemption of Baskets, paying transaction fees. They may encounter challenges in hedging XRP exposure and face potential slippage in cash creation transactions.
  • Service Providers, such as Coinbase Custody and BNY Mellon, receive fees for their services. However, the XRP Custodian and Prime Execution Agent have limited liability and shared insurance coverage, which could expose Trust assets to risk.
  • The XRP Ecosystem is impacted by the Trust's operations through its demand for XRP. However, the Trust's passive management means it will not actively influence the development or governance of the XRP Ledger. The fixed supply of XRP and significant holdings by Ripple Labs are noted as factors influencing market dynamics.

Next Steps

  • The Sponsor will continue to oversee service providers and manage the Trust's day-to-day operations.
  • The Sponsor may temporarily waive or rebate portions of the Sponsor Fee in its sole discretion.
  • The Sponsor may change the pricing benchmark with prior notice to Shareholders if investment conditions change or the current benchmark is deemed inaccurate.
  • The Trust will continue to comply with new or revised accounting standards on relevant dates for non-emerging growth companies.
  • The Sponsor will continue to monitor and evaluate the Trust's risk management processes and policies.
  • The Sponsor will continue to conduct due diligence on third-party service providers annually.
  • The Trust will continue to file all disclosures with respect to its Recovery Policy for Erroneously Awarded Incentive-Based Compensation.

Key Dates

DateDescription
January 4, 2024Effective Date of Recovery Policy for Erroneously Awarded Incentive-Based Compensation.
July 29, 2024CME CF XRP Dollar Reference Rate New York Variant (Pricing Benchmark) introduced.
July 13, 2023S.D.N.Y. issued key rulings in SEC vs. Ripple Labs case, finding XRP not inherently a security, but direct institutional sales were unregistered securities.
August 7, 2024S.D.N.Y. entered final judgment in SEC vs. Ripple Labs case, imposing a $125 million civil penalty and enjoining unregistered institutional sales.
October 10, 2025Bitwise Asset Management, Inc. (BAM) purchased 8 Seed Shares for $200.00.
October 31, 2025Trust formed as a Delaware statutory trust; First Amended and Restated Declaration of Trust and Trust Agreement dated; Sponsor Agreement dated.
November 19, 2025SEC declared Trust's Registration Statement on Form S-1 effective; BAM redeemed 8 Seed Shares for $200; Bitwise Investment Manager, LLC (BIM) purchased initial 100,000 Shares (Seed Baskets) for $2,277,445.
November 20, 2025Shares initially listed and began trading on NYSE Arca under ticker XRP. Sponsor Fee waiver period commenced.
December 19, 2025Sponsor Fee waiver period ended.
December 31, 2025Fiscal year end; Trust held 131,223,200.0749 XRP with market value of $239,758,000 (Principal Market NAV); Net assets $241,369,000; Net investment loss $25,000; Net unrealized depreciation $25,912,000.
January 21, 2025SEC's acting Chairman Mark T. Uyeda announced creation of the Crypto Task Force.
January 23, 2025President Trump executed 'Strengthening American Leadership in Digital Financial Technology Executive Order'.
February 2025Microsoft announced its Majorana 1 chip; SEC closed inquiry into PayPal USD stablecoin.
February 2025Coinbase entered into a joint stipulation with the SEC to dismiss the SEC's lawsuit against them with prejudice.
March 2025Kraken entered into a joint stipulation with the SEC to dismiss the SEC's lawsuit against them with prejudice.
April 2025Malware attack discovered in a widely used open-source JavaScript library associated with the XRP Ledger; SEC's Division of Corporation Finance staff issued a statement regarding Covered Stablecoins.
May 2025Binance entered into a joint stipulation with the SEC to dismiss the SEC's lawsuit against them with prejudice.
May 2025California, Louisiana, and Rhode Island adopted the Uniform Regulation of Virtual Currency Businesses Act.
July 2025U.S. President signed the Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (GENIUS Act) into law.
August 2025Ripple Labs and the SEC dropped their respective appeals, concluding the litigation.
December 2025CFTC withdrew certain interpretive guidance relating to 'retail commodity transactions' in digital assets.
March 2, 2026Date for beneficial ownership calculation.
March 12, 2026Trust sold 18,090,000 Shares for $390,263,381 since November 20, 2025.
March 20, 2026Date the financial statements were issued.
March 1, 2027Sponsor's principal office lease expires.

Recommendation

hold

The Bitwise XRP ETF has just commenced operations and experienced an initial decline in NAV per share due to XRP price depreciation. While recent regulatory clarity (dismissal of SEC lawsuits against major exchanges, new stablecoin legislation) provides a more stable backdrop for digital asset products, the inherent extreme volatility of XRP and the Trust's passive management strategy mean it will directly reflect these price swings. The initial fee waiver is attractive, but the long-term performance is entirely dependent on XRP's market trajectory. Investors should hold to observe how the ETF performs over a longer period and how XRP's price stabilizes or evolves within the new regulatory landscape, rather than making immediate buy or sell decisions based on this very short initial period.

Keywords

Bitwise XRP ETF, XRP, Cryptocurrency ETF, Digital Asset, SEC Filing, 10-K, Financial Report, Investment Trust, Blockchain, Ripple, Coinbase Custody, NYSE Arca, Asset Management, Regulatory Risk, Market Volatility, Grantor Trust, Financial Performance, Risk Factors, Passive Investment

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