Notice2025-10532

Self-Regulatory Organizations; NYSE Arca, Inc.; Notice of Filing of a Proposed Rule Change, as Modified by Amendment No. 1, To Amend the Bitwise Bitcoin ETF Trust and the Bitwise Ethereum ETF in Order To Permit In-Kind Creations and Redemptions

Primary source

Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.

Published
June 11, 2025

Issuing agencies

Securities and Exchange Commission

Full Text

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<title>Federal Register, Volume 90 Issue 111 (Wednesday, June 11, 2025)</title>
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[Federal Register Volume 90, Number 111 (Wednesday, June 11, 2025)]
[Notices]
[Pages 24683-24692]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2025-10532]


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SECURITIES AND EXCHANGE COMMISSION

[Release No. 34-103198; File No. SR-NYSEARCA-2025-38]


Self-Regulatory Organizations; NYSE Arca, Inc.; Notice of Filing 
of a Proposed Rule Change, as Modified by Amendment No. 1, To Amend the 
Bitwise Bitcoin ETF Trust and the Bitwise Ethereum ETF in Order To 
Permit In-Kind Creations and Redemptions

June 5, 2025.
    Pursuant to Section 19(b)(1) \1\ of the Securities Exchange Act of 
1934 (``Act'') \2\ and Rule 19b-4 thereunder,\3\ notice is hereby given 
that, on May 21, 2025, NYSE Arca, Inc. (``NYSE Arca'' or the 
``Exchange'') filed with the Securities and Exchange Commission (the 
``Commission'') the proposed rule change to amend the Bitwise Bitcoin 
ETF Trust and the Bitwise Ethereum ETF to permit in-kind creations and 
redemptions. On June 4, 2025, the Exchange filed Amendment No. 1 to the 
proposed rule change, which replaced and superseded the original filing 
in its entirety. The proposed rule change, as modified by Amendment No. 
1, is described in Items I, II, and III below, which Items have been 
prepared by the self-regulatory organization. The Commission is 
publishing this notice to solicit comments on the proposed rule change, 
as modified by Amendment No. 1, from interested persons.
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    \1\ 15 U.S.C. 78s(b)(1).
    \2\ 15 U.S.C. 78a.
    \3\ 17 CFR 240.19b-4.
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I. Self-Regulatory Organization's Statement of the Terms of Substance 
of the Proposed Rule Change, as Modified by Amendment No. 1

    The Exchange proposes to amend the Bitwise Bitcoin ETF Trust and 
the Bitwise Ethereum ETF, shares of which have been approved by the 
Commission to list and trade on the Exchange pursuant to Rule 8.201-E 
(Commodity-Based Trust Shares), to permit in-kind creations and 
redemptions. This Amendment No. 1 to SR-NYSEARCA-2025-38 replaces SR-
NYSEARCA-2025-38 as originally filed and supersedes such filing in its 
entirety. The proposed rule change is available on the Exchange's 
website at <a href="http://www.nyse.com">www.nyse.com</a>, at the principal office of the Exchange, and 
at the Commission's Public Reference Room.

II. Self-Regulatory Organization's Statement of the Purpose of, and 
Statutory Basis for, the Proposed Rule Change, as Modified by Amendment 
No. 1

    In its filing with the Commission, the self-regulatory organization 
included statements concerning the purpose of, and basis for, the 
proposed rule change and discussed any comments it received on the 
proposed rule change. The text of those statements may be examined at 
the places specified in Item IV below. The Exchange has prepared 
summaries, set forth in sections A, B, and C below, of the most 
significant parts of such statements.

A. Self-Regulatory Organization's Statement of the Purpose of, and the 
Statutory Basis for, the Proposed Rule Change

1. Purpose
    The Exchange proposes to amend the Bitwise Bitcoin ETF Trust (the 
``Bitcoin Trust'') and the Bitwise Ethereum ETF (the ``ETH Trust'' and, 
together with the Bitcoin Trust, the ``Trusts''), shares of which have 
been approved by the

[[Page 24684]]

Commission to list and trade on the Exchange pursuant to Rule 8.201-E 
(Commodity-Based Trust Shares), to permit in-kind creations and 
redemptions.
Background
    The Commission approved the listing and trading of shares 
(``Bitcoin Trust Shares'') of the Bitcoin Trust on the Exchange under 
Rule 8.201-E (Commodity-Based Trust Shares) on January 10, 2024.\4\ The 
Commission also approved the listing and trading of shares of the ETH 
Trust (``ETH Trust Shares'') under Rule 8.201-E (Commodity-Based Trust 
Shares) on May 23, 2024.\5\
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    \4\ See Securities Exchange Act Release No. 99306 (Jan. 10, 
2024), 89 FR 3008 (Jan. 17, 2024) (SR-NYSEArca-2023-44) (Order 
Granting Accelerated Approval of Proposed Rule Changes, as Modified 
by Amendments Thereto, To List and Trade Bitcoin-Based Commodity-
Based Trust Shares and Trust Units) (the ``Bitcoin Approval 
Order'').
    \5\ See Securities Exchange Act Release No. 100224 (May 23, 
2024), 89 FR 46937(May 30, 2024) (SR-NYSEArca-2024-31) (Order 
Granting Accelerated Approval of Proposed Rule Changes, as Modified 
by Amendments Thereto, To List and Trade Shares of Ether-Based 
Exchange Traded Products) (the ``Ether Approval Order'').
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    Rule 8.201-E governs the listing and trading of Commodity-Based 
Trust Shares. Commodity-Based Trust Shares are securities issued by a 
trust that represent investors' discrete identifiable and undivided 
beneficial ownership interest in the commodities deposited into the 
trust. The Bitcoin Trust Shares are issued by the Bitcoin Trust, a 
Delaware statutory trust, and the ETH ETP Shares are issued by the ETH 
Trust, also a Delaware statutory trust.
Proposed Rule Change--Bitcoin Trust
    The Exchange proposes to amend representations regarding the 
Bitcoin Trust's creation and redemption process as set forth in its 
previous rule filing to list and trade Bitcoin Trust Shares in order to 
allow for in-kind transfers of the Bitcoin Trust's bitcoin.\6\ The 
proposed in-kind transfer process will be an alternative to the Bitcoin 
Trust's current cash only creation and redemption process.
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    \6\ See Securities Exchange Act Release No. 99294 (Jan. 8, 
2024), 89 FR 2297 (Jan. 12, 2024) (SR-NYSEArca-2023-44) (Notice of 
Filing of Amendment No. 2 to a Proposed Rule Change To List and 
Trade Shares of the Bitwise Bitcoin ETF Under NYSE Arca Rule 8.201-E 
(Commodity-Based Trust Shares).
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    In order to effectuate this change, the Exchange proposes certain 
changes to Amendment No. 2 to the Bitcoin Trust Shares filing as 
described below. Except for the changes described below, all other 
representations in Amendment No. 2 remain unchanged and will continue 
to constitute continued listing requirements. In addition, the Bitcoin 
Trust will continue to comply with the terms of Amendment No. 2 and the 
requirements of Rule 8.201-E.
Operation of the Trust
    The Exchange proposes to amend the third paragraph in the section 
of Amendment No. 2 titled ``Operation of the Trust'' as follows 
(additions italicized): The Trust's only assets will be bitcoin and 
cash.\15\ The Trust does not seek to hold any non-bitcoin crypto assets 
and has expressly disclaimed ownership of any such assets in the event 
the Trust ever involuntarily comes into possession of such assets.\16\ 
The Trust will not use derivatives that may subject the Trust to 
counterparty and credit risks. The Trust will process creations and 
redemptions in cash or bitcoin. The Trust's only recurring ordinary 
expense is expected to be the Sponsor's unitary management fee (the 
``Sponsor Fee''), which will accrue daily and will be payable in 
bitcoin monthly in arrears. The Administrator will calculate the 
Sponsor Fee on a daily basis by applying an annualized rate to the 
Trust's total bitcoin holdings, and the amount of bitcoin payable in 
respect of each daily accrual shall be determined by reference to the 
CME US Reference Rate. Financial institutions authorized to create and 
redeem Shares (each, an ``Authorized Participant'') will deliver, or 
cause to be delivered, cash or bitcoin in exchange for Shares of the 
Trust, and the Trust will deliver cash or bitcoin to Authorized 
Participants when those Authorized Participants redeem Shares of the 
Trust.
    Footnote 15: The Trust conducts creations and redemptions of its 
Shares for cash or bitcoin. In connection with cash creations, 
Authorized Participants will deliver cash to the Cash Custodian 
pursuant to creation orders for Shares and the Cash Custodian will hold 
such cash until such time as it can be converted to bitcoin, which the 
Trust intends to do on the same business day in which such cash is 
received by the Cash Custodian. Additionally, the Trust will sell 
bitcoin in exchange for cash pursuant to cash redemption orders of its 
Shares. In connection with such sales, an approved Bitcoin Trading 
Counterparty (defined below) will send cash to the Cash Custodian. The 
Cash Custodian will hold such cash until it can be distributed to the 
redeeming Authorized Participant, which it intends to do on the same 
business in which it is received. In connection with the purchases and 
sales of bitcoin pursuant to its creation and redemption activity, it 
is possible that the Trust may retain de minimis amounts of cash as a 
result of rounding differences. The Trust may also initially hold small 
amounts of cash to initiate Trust operations in the immediate aftermath 
of its Registration Statement being declared effective. Lastly, the 
Trust may also sell bitcoin and temporarily hold cash as part of a 
liquidation of the Trust or to pay certain extraordinary expenses not 
assumed by the Sponsor. Under the Trust Agreement, the Sponsor has 
agreed to assume the normal operating expenses of the Trust, subject to 
certain limitations. For example, the Trust will bear any 
indemnification or litigation liabilities as extraordinary expenses. In 
any event, in the ongoing course of business, the amounts of cash 
retained by the Trust are not expected to constitute a material portion 
of the Trust's holdings. In connection with in-kind creations, 
Authorized Participants will submit orders by an order cutoff time to 
create ``Baskets'' of Shares in exchange for bitcoin. On the settlement 
date for an in-kind creation, the Trust delivers Shares to the 
Authorized Participant in exchange for bitcoin received from the 
Authorized Participant or its designated agent or client. The 
Authorized Participant or its designated agent or client will deposit 
such bitcoin with the Bitcoin Custodian. In connection with in-kind 
redemptions, the Authorized Participants will submit orders by an order 
cutoff time to redeem Baskets of Shares in exchange for bitcoin. On the 
settlement date for an in-kind redemption, the Trust delivers bitcoin 
to the account of the Authorized Participant or its designated agent or 
client in exchange for Shares received from the Authorized Participant.
    Footnote 16: No change.
Creation and Redemption of Shares
    The Exchange proposes to amend the section of Amendment No. 2 
titled ``Creation and Redemption of Shares'' to integrate the proposed 
in-kind creation and redemption process, as follows (additions 
italicized, deletions bracketed):
    The Trust creates and redeems Shares from time to time, but only in 
one or more Creation Units, which will initially consist of at least 
10,000 Shares, but may be subject to change (``Creation Unit''). A 
Creation Unit is only made in exchange for delivery to the Trust or the 
distribution by the Trust of an amount of cash or bitcoin, equivalent 
to the amount of bitcoin represented by the Creation Unit being created 
or redeemed, the amount of which is representative of the combined NAV 
of the number of Shares included in the Creation Units being created or 
redeemed determined as of 4:00 p.m.

[[Page 24685]]

E.T. on the day the order to create or redeem Creation Units is 
properly received. Except when aggregated in Creation Units or under 
extraordinary circumstances permitted under the Trust Agreement, the 
Shares are not redeemable securities.
    Authorized Participants are the only persons that may place orders 
to create and redeem Creation Units. Authorized Participants must be 
(1) registered broker-dealers or other securities market participants, 
such as banks and other financial institutions, that are not required 
to register as broker-dealers to engage in securities transactions 
described below, and (2) Depository Trust Company (``DTC'') 
Participants. To become an Authorized Participant, a person must enter 
into an Authorized Participant Agreement with the Trust and/or the 
Trust's marketing agent (the ``Marketing Agent'').
    According to the Registration Statement, when purchasing or selling 
bitcoin in response to the purchase of Creation Units or the redemption 
of Creation Units[, which will be processed in cash], the Trust would 
do so pursuant to either (1) a ``Trust-Directed Trade Model,'' or (2) 
an ``Agent Execution Model,'' which are each described in more detail 
below.
    The Trust intends to utilize the Trust-Directed Trade Model for all 
purchases and sales of bitcoin and would only utilize the Agent 
Execution Model in the event that no Bitcoin Trading Counterparty is 
able to effectuate the Trust's purchase or sale of bitcoin. Under the 
Trust-Directed Trade Model, in connection with receipt of a purchase 
order or redemption order, the Sponsor, on behalf of the Trust, would 
be responsible for acquiring bitcoin from an approved Bitcoin Trading 
Counterparty in an amount equal to the Basket Amount. When seeking to 
purchase bitcoin on behalf of the Trust, the Sponsor will seek to 
purchase bitcoin at commercially reasonable price and terms from any of 
the approved Bitcoin Trading Counterparties.\25\ Once agreed upon, the 
transaction will generally occur on an ``over-the-counter'' basis.
    [Whether utilizing the Trust-Directed Trade Model or the Agent 
Execution Model, the Authorized Participants will deliver only cash to 
create shares and will receive only cash when redeeming Shares. 
Further, Authorized Participants will not directly or indirectly 
purchase, hold, deliver, or receive bitcoin as part of the creation or 
redemption process or otherwise direct the trust or a third party with 
respect to purchasing, holding, delivering, or receiving bitcoin as 
part of the creation or redemption process. Additionally, under both 
the Trust-Directed Trade Model or the Agent Execution Model, the Trust 
will create Shares by receiving bitcoin from a third party that is not 
the Authorized Participant and is not affiliated with the Sponsor or 
the Trust, and the Trust--not the Authorized Participant--is 
responsible for selecting the third party to deliver the bitcoin. The 
third party will not be acting as an agent of the Authorized 
Participant with respect to the delivery of the bitcoin to the Trust or 
acting at the direction of the Authorized Participant with respect to 
the delivery of the bitcoin to the Trust. Additionally, the Trust will 
redeem Shares by delivering bitcoin to a third party that is not the 
Authorized Participant and is not affiliated with the Sponsor or the 
Trust, and the Trust--not the Authorized Participant--is responsible 
for selecting the third party to receive the bitcoin. Finally, the 
third party will not be acting as an agent of the Authorized 
Participant with respect to the receipt of the bitcoin from the Trust 
or acting at the direction of the Authorized Participant with respect 
to the receipt of the bitcoin from the Trust.]
    Footnote 25: No change.
Acquiring and Selling Bitcoin Pursuant to Creation and Redemption of 
Shares Under the Trust-Directed Model
    Under the Trust-Directed Trade Model and as set forth in the 
Registration Statement, on any business day, an Authorized Participant 
may create Shares by placing an order to purchase one or more Creation 
Units with the Transfer Agent through the Marketing Agent. Such orders 
are subject to approval by the Marketing Agent and the Transfer Agent. 
For purposes of processing creation and redemption orders, a ``business 
day'' means any day other than a day when the Exchange is closed for 
regular trading (``Business Day''). To be processed on the date 
submitted, creation orders must be placed before 4 p.m. E.T. or the 
close of regular trading on the Exchange, whichever is earlier, but may 
be required to be placed earlier at the discretion of the Sponsor. A 
purchase order will be effective on the date it is received by the 
Transfer Agent and approved by the Marketing Agent (``Purchase Order 
Date'').
    Creation Units are processed in cash or bitcoin. By placing a 
purchase order, an Authorized Participant agrees to deposit, or cause 
to be deposited, an amount of cash or bitcoin equal to the quantity of 
bitcoin attributable to each Share of the Trust (net of accrued but 
unpaid expenses and liabilities) multiplied by the number of Shares 
(10,000) comprising a Creation Unit (the ``Basket Amount''). The 
Sponsor will cause to be published each Business Day, prior to the 
commencement of trading on the Exchange, the Basket Amount relating to 
a Creation Unit applicable for such Business Day. That amount is 
derived by multiplying the Basket Amount by the value of bitcoin 
ascribed by the CME US Reference Rate. However, the Authorized 
Participant is also responsible for any additional cash or bitcoin 
required to account for the price at which the Trust agrees to purchase 
the requisite amount of bitcoin from a bitcoin trading counterparty 
approved by the Sponsor (``Bitcoin Trading Counterparty'')\26\ to the 
extent it is greater than the CME US Reference Rate price on each 
Purchase Order Date.
    Prior to the delivery of Creation Units, the Authorized Participant 
must also have wired to the Transfer Agent the nonrefundable 
transaction fee due for the creation order. Authorized Participants may 
not withdraw a creation request. If an Authorized Participant fails to 
consummate the foregoing, the order may be cancelled.
    Following the acceptance of a purchase order, [the Authorized 
Participant must wire the cash amount described above] in connection 
with a cash creation, the Authorized Participant must wire the cash 
amount to the Cash Custodian, and the Bitcoin Trading Counterparty must 
deposit the required amount of bitcoin with the Bitcoin Custodian by 
the end of the day E.T. on the Business Day following the Purchase 
Order Date. The bitcoin will be purchased from Bitcoin Trading 
Counterparties that are not acting as agents of the Trust or agents of 
the Authorized Participant. These transactions will be done on an arms-
length basis, and there is no contractual relationship between the 
Trust, the Sponsor, or the Bitcoin Trading Counterparty to acquire such 
bitcoin. Prior to any movement of cash from the Cash Custodian to the 
Bitcoin Trading Counterparty or movement of Shares from the Transfer 
Agent to the Authorized Participant's DTC account to settle the 
transaction, the bitcoin must be deposited at the Bitcoin Custodian.
    The Bitcoin Trading Counterparty must deposit the required amount 
of bitcoin by end of day E.T. on the Business Day following the 
Purchase Order Date prior to any movement of cash from the Cash 
Custodian or Shares from the Transfer Agent. Upon receipt of the 
deposit amount of bitcoin at the Bitcoin Custodian from the Bitcoin 
Trading Counterparty, the Bitcoin Custodian will notify the Sponsor 
that

[[Page 24686]]

the bitcoin has been received. The Sponsor will then notify the 
Transfer Agent that the bitcoin has been received, and the Transfer 
Agent will direct DTC to credit the number of Shares ordered to the 
Authorized Participant's DTC account and will wire the cash previously 
sent by the Authorized Participant to the Bitcoin Trading Counterparty 
to complete settlement of the Purchase Order and the acquisition of the 
bitcoin by the Trust, as described above.
    In connection with in-kind creations, the Authorized Participant 
must submit a purchase order by an order cutoff time (the ``In-Kind 
Order Cutoff Time'') to create Baskets of Shares in exchange for 
bitcoin. The In-Kind Order Cutoff Time will initially be 3:59 p.m. ET 
on the Purchase Order Date.
    On the settlement date for an in-kind creation, the Trust delivers 
Shares to the Authorized Participant in exchange for bitcoin received 
from the Authorized Participant or its designated agent or client. The 
Authorized Participant or its designated agent or client will deposit 
such bitcoin with the Bitcoin Custodian. In the event the Authorized 
Participant has not deposited the bitcoin with the Bitcoin Custodian by 
the applicable time on the settlement date of the in-kind purchase 
order, the Authorized Participant will be given the option to (1) 
cancel the in-kind purchase order, (2) delay settlement of the purchase 
order to enable delivery of bitcoin at a later date, or (3) accept that 
the Trust will execute a bitcoin transaction required for the creation 
and the Authorized Participant and the Authorized Participant will 
deliver the U.S. dollars required for the purchase order.
    As between the Trust and the Authorized Participant, the expense 
and risk of the difference between the value of bitcoin calculated by 
the Administrator for daily valuation using the CME US Reference Rate 
and the price at which the Trust acquires the bitcoin will be borne 
solely by the Authorized Participant to the extent that the Trust pays 
more for bitcoin than the price used by the Trust for daily valuation. 
[A]In connection with cash creations, any such additional cash amount 
will be included in the amount of cash calculated by the Administrator 
on the Purchase Order Date, communicated to the Authorized Participant 
on the Purchase Order Date, and wired by the Authorized Participant to 
the Cash Custodian on the day following the Purchase Order Date. If the 
Bitcoin Trading Counterparty fails to deliver the bitcoin to the 
Bitcoin Custodian, no cash is sent from the Cash Custodian to the 
Bitcoin Trading Counterparty, no Shares are transferred to the 
Authorized Participant's DTC account, the cash is returned to the 
Authorized Participant, and the Purchase Order is cancelled.
    Under the Trust-Directed Trade Model and according to the 
Registration Statement, the procedures by which an Authorized 
Participant can redeem one or more Creation Units mirror the procedures 
for the creation of Creation Units. On any Business Day, an Authorized 
Participant may place an order with the Transfer Agent through the 
Marketing Agent to redeem one or more Creation Units. To be processed 
on the date submitted, redemption orders must be placed before 4 p.m. 
E.T. or the close of regular trading on the Exchange, whichever is 
earlier, or earlier as determined by the Sponsor. A redemption order 
will be effective on the date it is received by the Transfer Agent and 
approved by the Marketing Agent (``Redemption Order Date''). The 
redemption procedures allow Authorized Participants to redeem Creation 
Units and do not entitle an individual shareholder to redeem any Shares 
in an amount less than a Creation Unit, or to redeem Creation Units 
other than through an Authorized Participant. In connection with 
receipt of a redemption order accepted by the Marketing Agent and 
Transfer Agent, the Sponsor, on behalf of the Trust, is responsible for 
selling the bitcoin to an approved Bitcoin Trading Counterparty in an 
amount equal to the Basket Amount.
    The redemption distribution from the Trust will consist of a 
transfer to the redeeming Authorized Participant, or its agent, of the 
amount of cash or bitcoin the Trust received in connection with a sale 
of the Basket Amount of bitcoin to a Bitcoin Trading Counterparty made 
pursuant to the redemption order. The Sponsor will cause to be 
published each Business Day, prior to the commencement of trading on 
the Exchange, the redemption distribution amount relating to a Creation 
Unit applicable for such Business Day. The redemption distribution 
amount is derived by multiplying the Basket Amount by the value of 
bitcoin ascribed by the CME US Reference Rate. However, as between the 
Trust and the Authorized Participant, the expense and risk of the 
difference between the value of bitcoin ascribed by the CME US 
Reference Rate and the price at which the Trust sells the bitcoin will 
be borne solely by the Authorized Participant to the extent that the 
Trust receives less for bitcoin than the value ascribed by CME US 
Reference Rate.
    Prior to the delivery of Creation Units, the Authorized Participant 
must also have wired to the Transfer Agent the nonrefundable 
transaction fee due for the redemption order.
    In connection with cash redemptions, [T]the redemption distribution 
due from the Trust will be delivered by the Transfer Agent to the 
Authorized Participant once the Cash Custodian has received the cash 
from the Bitcoin Trading Counterparty. The Bitcoin Custodian will not 
send the Basket Amount of bitcoin to the Bitcoin Trading Counterparty 
until the Cash Custodian has received the cash from the Bitcoin Trading 
Counterparty and is instructed by the Sponsor to make such transfer. 
Once the Bitcoin Trading Counterparty has sent the cash to the Cash 
Custodian in an agreed upon amount to settle the agreed upon sale of 
the Basket Amount of bitcoin, the Transfer Agent will notify Sponsor. 
The Sponsor will then notify the Bitcoin Custodian to transfer the 
bitcoin to the Bitcoin Trading Counterparty, and the Transfer Agent 
will wire the redemption proceeds to the Authorized Participant once 
the Trust's DTC account has been credited with the Shares represented 
by the Creation Unit from the redeeming Authorized Participant. Once 
the Authorized Participant has delivered the Shares represented by the 
Creation Unit to be redeemed to the Trust's DTC account, the Cash 
Custodian will wire the requisite amount of cash to the Authorized 
Participant. If the Trust's DTC account has not been credited with all 
of the Shares of the Creation Unit to be redeemed, the redemption 
distribution will be delayed until such time as the Transfer Agent 
confirms receipt of all such Shares. If the Bitcoin Trading 
Counterparty fails to deliver the cash to the Cash Custodian, the 
transaction will be cancelled, and no transfer of bitcoin or Shares 
will occur.
    In connection with in-kind redemptions, the Authorized Participant 
must submit an order by the In-Kind Order Cutoff Time to redeem Baskets 
of Shares in exchange for bitcoin. On the settlement date for an in-
kind redemption, the Trust delivers bitcoin to the Authorized 
Participant in exchange for Shares received from the Authorized 
Participant or its designated agent or client. The Authorized 
Participant or its designated agent or client will deposit such Shares 
to the Trust's DTC account.
    In the event the Authorized Participant has not deposited the 
Shares to the Trust's DTC account by the applicable time on the 
settlement date of the in-kind redemption order, the Authorized 
Participant will be given the option to (1) cancel the in-kind

[[Page 24687]]

redemption order, (2) delay settlement of the redemption order to 
enable delivery of Shares at a later date, or (3) accept that the Trust 
will execute a bitcoin transaction required for the redemption order 
and the Authorized Participant will be delivered the U.S. dollars 
required as calculated during the cash redemption process.
Acquiring and Selling Bitcoin Pursuant to Creation and Redemption of 
Shares Under the Agent Execution Model
    Under the Agent Execution Model, Coinbase, Inc. (``Coinbase Inc.'' 
or the ``Prime Execution Agent,'' an affiliate of the Bitcoin 
Custodian), acting in an agency capacity, would conduct bitcoin 
purchases and sales on behalf of the Trust with third parties through 
its Coinbase Prime service pursuant to the Prime Execution Agent 
Agreement. To utilize the Agent Execution Model, the Trust may maintain 
some bitcoin or cash in a trading account (the ``Trading Balance'') 
with the Prime Execution Agent. The Prime Execution Agent Agreement 
provides that the Trust does not have an identifiable claim to any 
particular bitcoin (and cash); rather, the Trust's Trading Balance 
represents an entitlement to a pro rata share of the bitcoin (and cash) 
the Prime Execution Agent holds on behalf of customers who hold similar 
entitlements against the Prime Execution Agent. In this way, the 
Trust's Trading Balance represents an omnibus claim on the Prime 
Execution Agent's bitcoins (and cash) held on behalf of the Prime 
Execution Agent's customers.
    To avoid having to pre-fund purchases or sales of bitcoin in 
connection with cash creations and redemptions and sales of bitcoin to 
pay Trust expenses not assumed by the Sponsor, to the extent 
applicable, the Trust may borrow bitcoin or cash as trade credit 
(``Trade Credit'') from Coinbase Credit, Inc. (the ``Trade Credit 
Lender'') on a short-term basis pursuant to the Coinbase Credit 
Committed Trade Financing Agreement (the ``Trade Financing 
Agreement'').
    For cash purchase orders, [O]on the day of the Purchase Order Date, 
the Trust would enter into a transaction to buy bitcoin through the 
Prime Execution Agent for cash. Because the Trust's Trading Balance may 
not be funded with cash on the Purchase Order Date for the purchase of 
bitcoin in connection with the Purchase Order under the Agent Execution 
Model, the Trust may borrow Trade Credits in the form of cash from the 
Trade Credit Lender pursuant to the Trade Financing Agreement or may 
require the Authorized Participant to deliver the required cash for the 
Purchase Order on the Purchase Order Date. The extension of Trade 
Credits on the Purchase Order Date allows the Trust to purchase bitcoin 
through the Prime Execution Agent on the Purchase Order Date, with such 
bitcoin being deposited in the Trust's Trading Balance.
    For cash purchase orders, [O]on the day following the Purchase 
Order Date (the ``Purchase Order Settlement Date''), the Trust would 
deliver Shares to the Authorized Participant in exchange for cash 
received from the Authorized Participant. Where applicable, the Trust 
would use the cash to repay the Trade Credits borrowed from the Trade 
Credit Lender. On the Purchase Order Settlement Date for a Purchase 
Order utilizing the Agent Execution Model, the bitcoin associated with 
the Purchase Order and purchased on the Purchase Order Date is swept 
from the Trust's Trading Balance with the Prime Execution Agent to the 
Trust Bitcoin Account with the Bitcoin Custodian pursuant to a regular 
end-of-day sweep process. Transfers of bitcoin into the Trust's Trading 
Balance are off-chain transactions and transfers from the Trust's 
Trading Balance to the Trust Bitcoin Account are ``on-chain'' 
transactions represented on the bitcoin blockchain. Any financing fee 
owed to the Trade Credit Lender is deemed part of trade execution costs 
and embedded in the trade price for each transaction.
    For a cash Redemption Order utilizing the Agent Execution Model, on 
the day of the Redemption Order Date the Trust would enter into a 
transaction to sell bitcoin through the Prime Execution Agent for cash. 
The Trust's Trading Balance with the Prime Execution Agent may not be 
funded with bitcoin on trade date for the sale of bitcoin in connection 
with the redemption order under the Agent Execution Model, when bitcoin 
remains in the Trust Bitcoin Account with the Bitcoin Custodian at the 
point of intended execution of a sale of bitcoin. In those 
circumstances the Trust may borrow Trade Credits in the form of bitcoin 
from the Trade Credit Lender, which allows the Trust to sell bitcoin 
through the Prime Execution Agent on the Redemption Order Date, and the 
cash proceeds are deposited in the Trust's Trading Balance with the 
Prime Execution Agent. On the business day following the Redemption 
Order Date (the ``Redemption Order Settlement Date'') for a redemption 
order utilizing the Agent Execution Model where Trade Credits were 
utilized, the Trust delivers cash to the Authorized Participant in 
exchange for Shares received from the Authorized Participant. In the 
event Trade Credits were used, the Trust will use the bitcoin that is 
moved from the Trust Bitcoin Account with the Bitcoin Custodian to the 
Trading Balance with the Prime Execution Agent to repay the Trade 
Credits borrowed from the Trade Credit Lender.
    For a cash redemption of Creation Units utilizing the Agent 
Execution Model, the Sponsor would instruct the Bitcoin Custodian to 
prepare to transfer the bitcoin associated with the redemption order 
from the Trust Bitcoin Account with the Bitcoin Custodian to the 
Trust's Trading Balance with the Prime Execution Agent. On the 
Redemption Order Settlement Date, the Trust would enter into a 
transaction to sell bitcoin through the Prime Execution Agent for cash, 
and the Prime Execution Agent credits the Trust's Trading Balance with 
the cash. On the same day, the Authorized Participant would deliver the 
necessary Shares to the Trust and the Trust delivers cash to the 
Authorized Participant.
    Footnote 26: No change.
Proposed Rule Change--ETH Trust
    Similarly, the Exchange proposes to amend representations regarding 
the ETH Trust's creation and redemption process as set forth in its 
previous rule filing to list and trade ETH Trust Shares to allow for 
in-kind transfers of the ETH Trust's ether. The proposed in-kind 
transfer process will be an alternative to the ETH Trust's current cash 
creation and redemption process.
    In order to effectuate this change, the Exchange proposes certain 
changes to Amendment No. 1 to the ETH Trust Shares filing as described 
below.\7\ Except for the changes described below, all other 
representations in Amendment No. 1 remain unchanged and will continue 
to constitute continued listing requirements. In addition, the Trust 
will continue to comply with the terms of Amendment No. 1 and the 
requirements in Rule 8.201-E.
---------------------------------------------------------------------------

    \7\ See Securities Exchange Act Release No. 100213 (May 22, 
2024), 89 FR 46533 (May 29, 2024) (SR-NYSEArca-2024-31) (Notice of 
Filing of Amendment No. 1 to a Proposed Rule Change To List and 
Trade Shares of the Bitwise Ethereum ETF).
---------------------------------------------------------------------------

Operation of the Trust
    The Exchange proposes to amend the third paragraph in the section 
of Amendment No. 1 titled ``Operation of the Trust'' as follows 
(additions italicized):
    The Trust's only assets will be ether and cash.\11\ The Trust does 
not seek to hold any non-ether crypto assets and has expressly 
disclaimed ownership of any such assets in the event the Trust

[[Page 24688]]

ever involuntarily comes into possession of such assets.\12\ The Trust 
will not use derivatives that may subject the Trust to counterparty and 
credit risks. The Trust will process creations and redemptions in cash 
or ether. The Trust's only recurring ordinary expense is expected to be 
the Sponsor's unitary management fee (the ``Sponsor Fee''), which will 
accrue daily and will be payable in ether monthly in arrears. The 
Administrator will calculate the Sponsor Fee on a daily basis by 
applying an annualized rate to the Trust's total ether holdings, and 
the amount of ether payable in respect of each daily accrual shall be 
determined by reference to the Pricing Index. Financial institutions 
authorized to create and redeem Shares (each, an ``Authorized 
Participant'') will deliver, or cause to be delivered, cash or ether in 
exchange for Shares of the Trust, and the Trust will deliver cash to 
Authorized Participants when those Authorized Participants redeem 
Shares of the Trust.
    Footnote 11: The Trust conducts creations and redemptions of its 
Shares for cash or ether. In connection with cash creations, Authorized 
Participants will deliver cash to the Cash Custodian pursuant to 
creation orders for Shares and the Cash Custodian will hold such cash 
until such time as it can be converted to ether, which the Trust 
intends to do on the same business day in which such cash is received 
by the Cash Custodian. Additionally, the Trust will sell ether in 
exchange for cash pursuant to cash redemption orders of its Shares. In 
connection with such sales, an approved Ether Trading Counterparty 
(defined below) will send cash to the Cash Custodian. The Cash 
Custodian will hold such cash until it can be distributed to the 
redeeming Authorized Participant, which it intends to do on the same 
business in which it is received. In connection with the purchases and 
sales of ether pursuant to its creation and redemption activity, it is 
possible that the Trust may retain de minimis amounts of cash as a 
result of rounding differences. The Trust may also initially hold small 
amounts of cash to initiate Trust operations in the immediate aftermath 
of its Registration Statement being declared effective. Lastly, the 
Trust may also sell ether and temporarily hold cash as part of a 
liquidation of the Trust or to pay certain extraordinary expenses not 
assumed by the Sponsor. Under the Trust Agreement, the Sponsor has 
agreed to assume the normal operating expenses of the Trust, subject to 
certain limitations. For example, the Trust will bear any 
indemnification or litigation liabilities as extraordinary expenses. In 
any event, in the ongoing course of business, the amounts of cash 
retained by the Trust are not expected to constitute a material portion 
of the Trust's holdings. In connection with in-kind creations, 
Authorized Participants will submit orders by an order cutoff time to 
create ``Baskets'' of Shares in exchange for ether. On the settlement 
date for an in-kind creation, the Trust delivers Shares to the 
Authorized Participant in exchange for ether received from the 
Authorized Participant or its designated agent or client. The 
Authorized Participant or its designated agent or client will deposit 
such ether with the Ether Custodian. In connection with in-kind 
redemptions, the Authorized Participants will submit orders by an order 
cutoff time to redeem Baskets of Shares in exchange for ether. On the 
settlement date for an in-kind redemption, the Trust delivers ether to 
the account of the Authorized Participant or its designated agent or 
client in exchange for Shares received from the Authorized Participant.
    Footnote 12: No Change.
Creation and Redemption of Shares
    The Exchange proposes to amend the sections of Amendment No. 1 
titled ``Creation and Redemption of Shares'' to integrate the proposed 
in-kind creation and redemption process, as follows (additions 
italicized, deletions bracketed):
    The Trust creates and redeems Shares from time to time, but only in 
one or more Creation Units, which will initially consist of at least 
10,000 Shares, but may be subject to change (``Creation Unit''). A 
Creation Unit is only made in exchange for delivery to the Trust or the 
distribution by the Trust of an amount of cash, equivalent to the value 
of ether represented by the Creation Unit being created or redeemed, 
the amount of which is representative of the combined NAV of the number 
of Shares included in the Creation Units being created or redeemed 
determined as of 4:00 p.m. E.T. on the day the order to create or 
redeem Creation Units is properly received. Except when aggregated in 
Creation Units or under extraordinary circumstances permitted under the 
Trust Agreement, the Shares are not redeemable securities.
    Authorized Participants are the only persons that may place orders 
to create and redeem Creation Units. Authorized Participants must be 
(1) registered broker-dealers or other securities market participants, 
such as banks and other financial institutions, that are not required 
to register as broker-dealers to engage in securities transactions 
described below, and (2) Depository Trust Company (``DTC'') 
participants. To become an Authorized Participant, a person must enter 
into an Authorized Participant Agreement with the Trust and/or the 
Trust's marketing agent (the ``Marketing Agent'').
    According to the Registration Statement, when purchasing or selling 
ether in response to the purchase of Creation Units or the redemption 
of Creation Units[, which will be processed in cash], the Trust would 
do so pursuant to either (1) a ``Trust-Directed Trade Model,'' or (2) 
an ``Agent Execution Model,'' which are each described in more detail 
below.
    The Trust intends to utilize the Trust-Directed Trade Model for all 
purchases and sales of ether and would only utilize the Agent Execution 
Model in the event that no ether trading counterparty approved by the 
Sponsor (an ``Ether Trading Counterparty'')\15\ is able to effectuate 
the Trust's purchase or sale of ether. Under the Trust-Directed Trade 
Model, in connection with receipt of a purchase order or redemption 
order, the Sponsor, on behalf of the Trust, would be responsible for 
acquiring ether from an approved Ether Trading Counterparty in an 
amount equal to the Basket Amount. When seeking to purchase ether on 
behalf of the Trust, the Sponsor will seek to purchase ether at 
commercially reasonable price and terms from any of the approved Ether 
Trading Counterparties.\16\ Once agreed upon, the transaction will 
generally occur on an ``over-the-counter'' basis.
    Footnote 15: No change.
    Footnote 16: No change.
    [Whether utilizing the Trust-Directed Trade Model or the Agent 
Execution Model, the Authorized Participants will deliver only cash to 
create shares and will receive only cash when redeeming Shares. 
Further, Authorized Participants will not directly or indirectly 
purchase, hold, deliver, or receive ether as part of the creation or 
redemption process or otherwise direct the Trust or a third party with 
respect to purchasing, holding, delivering, or receiving ether as part 
of the creation or redemption process. Additionally, under either the 
Trust-Directed Trade Model or the Agent Execution Model, the Trust will 
create Shares by receiving ether from a third party that is not the 
Authorized Participant and is not affiliated with the Sponsor or the 
Trust, and the Trust--not the Authorized Participant--is responsible 
for selecting the third party to deliver the ether. The third party 
will not be acting as an agent of the Authorized Participant with 
respect to

[[Page 24689]]

the delivery of the ether to the Trust or acting at the direction of 
the Authorized Participant with respect to the delivery of the ether to 
the Trust. Additionally, the Trust will redeem Shares by delivering 
ether to a third party that is not the Authorized Participant and is 
not affiliated with the Sponsor or the Trust, and the Trust--not the 
Authorized Participant--is responsible for selecting the third party to 
receive the ether. Finally, the third party will not be acting as an 
agent of the Authorized Participant with respect to the receipt of the 
ether from the Trust or acting at the direction of the Authorized 
Participant with respect to the receipt of the ether from the Trust.]
Acquiring and Selling Ether Pursuant to Creation and Redemption of 
Shares Under the Trust-Directed Trade Model
    Under the Trust-Directed Trade Model and as set forth in the 
Registration Statement, on any business day, an Authorized Participant 
may create Shares by placing an order to purchase one or more Creation 
Units with the Transfer Agent through the Marketing Agent. Such orders 
are subject to approval by the Marketing Agent and the Transfer Agent. 
For purposes of processing creation and redemption orders, a ``business 
day'' means any day other than a day when the Exchange is closed for 
regular trading (``Business Day''). To be processed on the date 
submitted, creation orders must be placed before 4:00 p.m. E.T. or the 
close of regular trading on the Exchange, whichever is earlier, but may 
be required to be placed earlier at the discretion of the Sponsor. A 
purchase order will be effective on the date it is received by the 
Transfer Agent and approved by the Marketing Agent (``Purchase Order 
Date'').
    Creation Units are processed in cash or ether. By placing a 
purchase order, an Authorized Participant agrees to deposit, or cause 
to be deposited, an amount of cash or ether equal to the quantity of 
ether attributable to each Share of the Trust (net of accrued but 
unpaid expenses and liabilities) multiplied by the number of Shares 
(10,000) comprising a Creation Unit (the ``Basket Amount''). The 
Sponsor will cause to be published each Business Day, prior to the 
commencement of trading on the Exchange, the Basket Amount relating to 
a Creation Unit applicable for such Business Day. That amount is 
derived by multiplying the Basket Amount by the value of ether ascribed 
by the Pricing Index. However, the Authorized Participant is also 
responsible for any additional cash or ether required to account for 
the price at which the Trust agrees to purchase the requisite amount of 
ether from an Ether Trading Counterparty to the extent it is greater 
than the Pricing Index price on each Purchase Order Date.
    Prior to the delivery of Creation Units, the Authorized Participant 
must also have wired to the Transfer Agent the nonrefundable 
transaction fee due for the creation order. Authorized Participants may 
not withdraw a creation request. If an Authorized Participant fails to 
consummate the foregoing, the order may be cancelled.
    Following the acceptance of a purchase order, the Authorized 
Participant must wire the [cash amount] Basket Amount described above. 
In connection with cash creations, the Authorized Participant must wire 
the cash amount to the Cash Custodian, and the Ether Trading 
Counterparty must deposit the required amount of ether with the Ether 
Custodian by the end of the day E.T. on the Business Day following the 
Purchase Order Date. The ether will be purchased from Ether Trading 
Counterparties that are not acting as agents of the Trust or agents of 
the Authorized Participant. These transactions will be done on an arms-
length basis, and there is no contractual relationship between the 
Trust, the Sponsor, or the Ether Trading Counterparty to acquire such 
ether. Prior to any movement of cash from the Cash Custodian to the 
Ether Trading Counterparty or movement of Shares from the Transfer 
Agent to the Authorized Participant's DTC account to settle the 
transaction, the ether must be deposited at the Ether Custodian.
    The Ether Trading Counterparty must deposit the required amount of 
ether by end of day E.T. on the Business Day following the Purchase 
Order Date prior to any movement of cash from the Cash Custodian or 
Shares from the Transfer Agent. Upon receipt of the deposit amount of 
ether at the Ether Custodian from the Ether Trading Counterparty, the 
Ether Custodian will notify the Sponsor that the ether has been 
received. The Sponsor will then notify the Transfer Agent that the 
ether has been received, and the Transfer Agent will direct DTC to 
credit the number of Shares ordered to the Authorized Participant's DTC 
account and will wire the cash previously sent by the Authorized 
Participant to the Ether Trading Counterparty to complete settlement of 
the Purchase Order and the acquisition of the ether by the Trust, as 
described above.
    In connection with in-kind creations, the Authorized Participant 
must submit a purchase order by an order cutoff time (the ``In-Kind 
Order Cutoff Time'') to create Baskets of Shares in exchange for ether. 
The In-Kind Order Cutoff Time will initially be 3:59 p.m. ET on the 
Purchase Order Date.
    On the settlement date for an in-kind creation, the Trust delivers 
Shares to the Authorized Participant in exchange for ether received 
from the Authorized Participant or its designated agent or client. The 
Authorized Participant or its designated agent or client will deposit 
such ether with the Ether Custodian. In the event the Authorized 
Participant has not deposited the ether with the Ether Custodian by the 
applicable time on the settlement date of the in-kind purchase order, 
the Authorized Participant will be given the option to (1) cancel the 
in-kind purchase order, (2) delay settlement of the purchase order to 
enable delivery of ether at a later date, or (3) accept that the Trust 
will execute a ether transaction required for the creation and the 
Authorized Participant and the Authorized Participant will deliver the 
U.S. dollars required for the purchase order.
    As between the Trust and the Authorized Participant, the expense 
and risk of the difference between the value of ether calculated by the 
Administrator for daily valuation using the Pricing Index and the price 
at which the Trust acquires the ether will be borne solely by the 
Authorized Participant to the extent that the Trust pays more for ether 
than the price used by the Trust for daily valuation. In connection 
with cash creations, [A]any such additional cash amount will be 
included in the amount of cash calculated by the Administrator on the 
Purchase Order Date, communicated to the Authorized Participant on the 
Purchase Order Date, and wired by the Authorized Participant to the 
Cash Custodian on the day following the Purchase Order Date. If the 
Ether Trading Counterparty fails to deliver the ether to the Ether 
Custodian, no cash is sent from the Cash Custodian to the Ether Trading 
Counterparty, no Shares are transferred to the Authorized Participant's 
DTC account, the cash is returned to the Authorized Participant, and 
the Purchase Order is cancelled.
    Under the Trust-Directed Trade Model and according to the 
Registration Statement, the procedures by which an Authorized 
Participant can redeem one or more Creation Units mirror the procedures 
for the creation of Creation Units. On any Business Day, an Authorized 
Participant may place an order with the Transfer Agent through the 
Marketing Agent to redeem one or more Creation Units. To be processed 
on the date submitted, redemption orders must be placed before 4:00 
p.m. E.T. or the close of regular trading on the

[[Page 24690]]

Exchange, whichever is earlier, or earlier as determined by the 
Sponsor. A redemption order will be effective on the date it is 
received by the Transfer Agent and approved by the Marketing Agent 
(``Redemption Order Date''). The redemption procedures allow Authorized 
Participants to redeem Creation Units and do not entitle an individual 
shareholder to redeem any Shares in an amount less than a Creation 
Unit, or to redeem Creation Units other than through an Authorized 
Participant. In connection with receipt of a redemption order accepted 
by the Marketing Agent and Transfer Agent, the Sponsor, on behalf of 
the Trust, is responsible for selling the ether to an approved Ether 
Trading Counterparty in an amount equal to the Basket Amount.
    The redemption distribution from the Trust will consist of a 
transfer to the redeeming Authorized Participant, or its agent, of the 
amount of cash or ether the Trust received in connection with a sale of 
the Basket Amount of ether to an Ether Trading Counterparty made 
pursuant to the redemption order. The Sponsor will cause to be 
published each Business Day, prior to the commencement of trading on 
the Exchange, the redemption distribution amount relating to a Creation 
Unit applicable for such Business Day. The redemption distribution 
amount is derived by multiplying the Basket Amount by the value of 
ether ascribed by the Pricing Index. However, as between the Trust and 
the Authorized Participant, the expense and risk of the difference 
between the value of ether ascribed by the Pricing Index and the price 
at which the Trust sells the ether will be borne solely by the 
Authorized Participant to the extent that the Trust receives less for 
ether than the value ascribed by Pricing Index.
    Prior to the delivery of Creation Units, the Authorized Participant 
must also have wired to the Transfer Agent the nonrefundable 
transaction fee due for the redemption order.
    In connection with cash redemptions, [T]the redemption distribution 
due from the Trust will be delivered by the Transfer Agent to the 
Authorized Participant once the Cash Custodian has received the cash 
from the Ether Trading Counterparty. The Ether Custodian will not send 
the Basket Amount of ether to the Ether Trading Counterparty until the 
Cash Custodian has received the cash from the Ether Trading 
Counterparty and is instructed by the Sponsor to make such transfer. 
Once the Ether Trading Counterparty has sent the cash to the Cash 
Custodian in an agreed upon amount to settle the agreed upon sale of 
the Basket Amount of ether, the Transfer Agent will notify Sponsor. The 
Sponsor will then notify the Ether Custodian to transfer the ether to 
the Ether Trading Counterparty, and the Transfer Agent will wire the 
cash proceeds to the Authorized Participant once the Trust's DTC 
account has been credited with the Shares represented by the Creation 
Unit from the redeeming Authorized Participant. Once the Authorized 
Participant has delivered the Shares represented by the Creation Unit 
to be redeemed to the Trust's DTC account, the Cash Custodian will wire 
the requisite amount of cash to the Authorized Participant. If the 
Trust's DTC account has not been credited with all of the Shares of the 
Creation Unit to be redeemed, the redemption distribution will be 
delayed until such time as the Transfer Agent confirms receipt of all 
such Shares. If the Ether Trading Counterparty fails to deliver the 
cash to the Cash Custodian, the transaction will be cancelled, and no 
transfer of ether or Shares will occur.
    In connection with in-kind redemptions, the Authorized Participant 
must submit an order by the In-Kind Order Cutoff Time to redeem Baskets 
of Shares in exchange for ether. On the settlement date for an in-kind 
redemption, the Trust delivers ether to the Authorized Participant in 
exchange for Shares received from the Authorized Participant or its 
designated agent or client. The Authorized Participant or its 
designated agent or client will deposit such Shares to the Trust's DTC 
account.
    In the event the Authorized Participant has not deposited the 
Shares to the Trust's DTC account by the applicable time on the 
settlement date of the in-kind redemption order, the Authorized 
Participant will be given the option to (1) cancel the in-kind 
redemption order, (2) delay settlement of the redemption order to 
enable delivery of Shares at a later date, or (3) accept that the Trust 
will execute a ether transaction required for the redemption order and 
the Authorized Participant will be delivered the U.S. dollars required 
as calculated during the cash redemption process.
Acquiring and Selling Ether Pursuant to Creation and Redemption of 
Shares Under the Agent Execution Model
    Under the Agent Execution Model, the Prime Execution Agent, acting 
in an agency capacity, would conduct ether purchases and sales on 
behalf of the Trust with third parties through its Coinbase Prime 
service pursuant to the Prime Execution Agent Agreement. To utilize the 
Agent Execution Model, the Trust may maintain some ether or cash in the 
Trading Balance with the Prime Execution Agent. The Prime Execution 
Agent Agreement provides that the Trust does not have an identifiable 
claim to any particular ether (and cash); rather, the Trust's Trading 
Balance represents an entitlement to a pro rata share of the ether (and 
cash) the Prime Execution Agent holds on behalf of customers who hold 
similar entitlements against the Prime Execution Agent. In this way, 
the Trust's Trading Balance represents an omnibus claim on the Prime 
Execution Agent's ether (and cash) held on behalf of the Prime 
Execution Agent's customers.
    To avoid having to pre-fund purchases or sales of ether in 
connection with cash creations and redemptions and sales of ether to 
pay Trust expenses not assumed by the Sponsor, to the extent 
applicable, the Trust may borrow ether or cash as trade credit (``Trade 
Credit'') from Coinbase Credit, Inc. (the ``Trade Credit Lender'') on a 
short-term basis pursuant to the Coinbase Credit Committed Trade 
Financing Agreement (the ``Trade Financing Agreement'').
    For cash purchase orders, [O]on the day of the Purchase Order Date, 
the Trust would enter into a transaction to buy ether through the Prime 
Execution Agent for cash. Because the Trust's Trading Balance may not 
be funded with cash on the Purchase Order Date for the purchase of 
ether in connection with the Purchase Order under the Agent Execution 
Model, the Trust may borrow Trade Credits in the form of cash from the 
Trade Credit Lender pursuant to the Trade Financing Agreement or may 
require the Authorized Participant to deliver the required cash for the 
Purchase Order on the Purchase Order Date. The extension of Trade 
Credits on the Purchase Order Date allows the Trust to purchase ether 
through the Prime Execution Agent on the Purchase Order Date, with such 
ether being deposited in the Trust's Trading Balance.
    For cash purchase orders, [O]on the day following the Purchase 
Order Date (the ``Purchase Order Settlement Date''), the Trust would 
deliver Shares to the Authorized Participant in exchange for cash 
received from the Authorized Participant. Where applicable, the Trust 
would use the cash to repay the Trade Credits borrowed from the Trade 
Credit Lender. On the Purchase Order Settlement Date for a Purchase 
Order utilizing the Agent Execution Model, the ether associated with 
the Purchase Order and purchased on the Purchase Order Date is swept 
from the Trust's Trading Balance with the Prime Execution Agent to the 
Trust Ether

[[Page 24691]]

Account with the Ether Custodian pursuant to a regular end-of-day sweep 
process. Transfers of ether into the Trust's Trading Balance are off-
chain transactions and transfers from the Trust's Trading Balance to 
the Trust Ether Account are ``on-chain'' transactions represented on 
the ether blockchain. Any financing fee owed to the Trade Credit Lender 
is deemed part of trade execution costs and embedded in the trade price 
for each transaction.
    For a cash Redemption Order utilizing the Agent Execution Model, on 
the day of the Redemption Order Date the Trust would enter into a 
transaction to sell ether through the Prime Execution Agent for cash. 
The Trust's Trading Balance with the Prime Execution Agent may not be 
funded with ether on trade date for the sale of ether in connection 
with the redemption order under the Agent Execution Model, when ether 
remains in the Trust Ether Account with the Ether Custodian at the 
point of intended execution of a sale of ether. In those circumstances 
the Trust may borrow Trade Credits in the form of ether from the Trade 
Credit Lender, which allows the Trust to sell ether through the Prime 
Execution Agent on the Redemption Order Date, and the cash proceeds are 
deposited in the Trust's Trading Balance with the Prime Execution 
Agent. On the business day following the Redemption Order Date (the 
``Redemption Order Settlement Date'') for a redemption order utilizing 
the Agent Execution Model where Trade Credits were utilized, the Trust 
delivers cash to the Authorized Participant in exchange for Shares 
received from the Authorized Participant. In the event Trade Credits 
were used, the Trust will use the ether that is moved from the Trust 
Ether Account with the Ether Custodian to the Trading Balance with the 
Prime Execution Agent to repay the Trade Credits borrowed from the 
Trade Credit Lender.
    For a cash redemption of Creation Units utilizing the Agent 
Execution Model, the Sponsor would instruct the Ether Custodian to 
prepare to transfer the ether associated with the redemption order from 
the Trust Ether Account with the Ether Custodian to the Trust's Trading 
Balance with the Prime Execution Agent. On the Redemption Order 
Settlement Date, the Trust would enter into a transaction to sell ether 
through the Prime Execution Agent for cash, and the Prime Execution 
Agent credits the Trust's Trading Balance with the cash. On the same 
day, the Authorized Participant would deliver the necessary Shares to 
the Trust and the Trust delivers cash to the Authorized Participant.
2. Statutory Basis
    The Exchange believes the proposed rule change is consistent with 
the Act and the rules and regulations thereunder applicable to the 
Exchange and, in particular, the requirements of Section 6(b) \8\ of 
the Act. Specifically, the Exchange believes the proposed rule change 
is consistent with the Section 6(b)(5) \9\ requirements that the rules 
of an exchange be designed to prevent fraudulent and manipulative acts 
and practices, to promote just and equitable principles of trade, to 
foster cooperation and coordination with persons engaged in regulating, 
clearing, settling, processing information with respect to, and 
facilitating transactions in securities, to remove impediments to and 
perfect the mechanism of a free and open market and a national market 
system, and, in general, to protect investors and the public interest.
---------------------------------------------------------------------------

    \8\ 15 U.S.C. 78f(b)(5).
    \9\ 15 U.S.C. 78f(b)(5).
---------------------------------------------------------------------------

    The Exchange believes the proposed rule change is designed to 
remove impediments to and perfect the mechanism of a free and open 
market and, in general, to protect investors and the public interest 
because it would update representations in both the Amendment No. 2 to 
the Bitcoin Trust Shares filing and Amendment No. 1 to the ETH Trust 
Shares filing such that the respective Trusts would both be able to 
engage in in-kind transactions with Authorized Participants, as 
described above. This ability would make the Trusts (and the market 
more generally) operate more efficiently because Authorized 
Participants would be able to source bitcoin or ether, as applicable, 
rather than provide cash to the applicable Trust and/or to receive 
bitcoin or ether, as applicable, directly from the Trusts. In-kind 
creations and redemptions would allow Authorized Participants to be 
responsible for buying and selling the applicable crypto asset rather 
than the Trusts, which would potentially lessen the impact on the 
market of the Trusts on both sides of the transaction by allowing the 
Authorized Participants to decide how and where to source the 
underlying crypto asset for creations and deciding how, where, and 
whether to sell the underlying crypto asset for redemptions. This would 
improve the creation and redemption process for both Authorized 
Participants and the Trusts, increase efficiency, and ultimately 
benefit the end investors in the Trusts.
    As noted above, except for the addition of in-kind creation and 
redemption for the Bitcoin Trust, all other representations made in the 
Amendment No. 2 to the Bitcoin Trust Shares filing remain unchanged and 
will continue to constitute continuing listing requirements for the 
Bitcoin Trust. Similarly, except for the addition of in-kind creation 
and redemption for the ETH Trust, all other representations made in 
Amendment No. 1 to the ETH Trust Shares filing remain unchanged and 
will continue to constitute continuing listing requirements for the ETH 
Trust.
    Accordingly, the Exchange believes that this proposed rule change 
raises no novel regulatory issues.

B. Self-Regulatory Organization's Statement on Burden on Competition

    The Exchange does not believe that the proposed rule change will 
impose any burden on competition that is not necessary or appropriate 
in furtherance of the purpose of the Act. As discussed above, the 
proposed amendments are intended to reflect changes to the Trusts' 
creation and redemption processes, specifically to allow for in-kind 
transfers.

C. Self-Regulatory Organization's Statement on Comments on the Proposed 
Rule Change Received From Members, Participants, or Others

    No written comments were solicited or received with respect to the 
proposed rule change.

III. Date of Effectiveness of the Proposed Rule Change, as Modified by 
Amendment No. 1, and Timing for Commission Action

    Within 45 days of the date of publication of this notice in the 
Federal Register or within such longer period up to 90 days (i) as the 
Commission may designate if it finds such longer period to be 
appropriate and publishes its reasons for so finding or (ii) as to 
which the self-regulatory organization consents, the Commission will:
    (A) by order approve or disapprove the proposed rule change, or
    (B) institute proceedings to determine whether the proposed rule 
change should be disapproved.

IV. Solicitation of Comments

    Interested persons are invited to submit written data, views and 
arguments concerning the foregoing, including whether the proposed rule 
change, as modified by Amendment No. 1, is consistent with the Act. 
Comments may be submitted by any of the following methods:

[[Page 24692]]

Electronic Comments

    <bullet> Use the Commission's internet comment form (<a href="https://www.sec.gov/rules/sro.shtml">https://www.sec.gov/rules/sro.shtml</a>); or
    <bullet> Send an email to <a href="/cdn-cgi/l/email-protection#0371766f662e606c6e6e666d7770437066602d646c75"><span class="__cf_email__" data-cfemail="99ebecf5fcb4faf6f4f4fcf7edead9eafcfab7fef6ef">[email&#160;protected]</span></a>. Please include 
file number SR-NYSEARCA-2025-38 on the subject line.

Paper Comments

    <bullet> Send paper comments in triplicate to Secretary, Securities 
and Exchange Commission, 100 F Street NE, Washington, DC 20549-1090.

All submissions should refer to file number SR-NYSEARCA-2025-38. This 
file number should be included on the subject line if email is used. To 
help the Commission process and review your comments more efficiently, 
please use only one method. The Commission will post all comments on 
the Commission's internet website (<a href="https://www.sec.gov/rules/sro.shtml">https://www.sec.gov/rules/sro.shtml</a>). Copies of the submission, all subsequent amendments, all 
written statements with respect to the proposed rule change that are 
filed with the Commission, and all written communications relating to 
the proposed rule change between the Commission and any person, other 
than those that may be withheld from the public in accordance with the 
provisions of 5 U.S.C. 552, will be available for website viewing and 
printing in the Commission's Public Reference Room, 100 F Street NE, 
Washington, DC 20549, on official business days between the hours of 10 
a.m. and 3 p.m. Copies of the filing also will be available for 
inspection and copying at the principal office of the Exchange. Do not 
include personal identifiable information in submissions; you should 
submit only information that you wish to make available publicly. We 
may redact in part or withhold entirely from publication submitted 
material that is obscene or subject to copyright protection. All 
submissions should refer to file number SR-NYSEARCA-2025-38 and should 
be submitted on or before July 2, 2025.

    For the Commission, by the Division of Trading and Markets, 
pursuant to delegated authority.\10\
---------------------------------------------------------------------------

    \10\ 17 CFR 200.30-3(a)(12).
---------------------------------------------------------------------------

Sherry R. Haywood,
Assistant Secretary.
[FR Doc. 2025-10532 Filed 6-10-25; 8:45 am]
BILLING CODE 8011-01-P


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Indexed from Federal Register on June 11, 2025.

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