Bitwise USCC

Rejected venues wait the longest for re-review; a rejection has to earn another look before the scheduled date.

The Bitwise Crypto Carry Fund is a private Delaware statutory-trust series for qualified purchasers. It issues the same fund shares as USCC tokens or book-entry records while an investment manager trades crypto spot, staking assets, futures and government securities. Bitwise reported $139.18M of total AUM on 2026-08-15; DefiLlama’s narrower $56.1M tracks only onchain shares, so the former below-materiality basis was false. The correct v1 class is off-chain credit and basis trading: token controls are visible, but decisive portfolio, margin, counterparty, valuation and redemption records remain manager-, custodian- and venue-dependent. Rejected under that shared rule, not because of a known fund impairment.

Kill criteria: the events that revoke this verdict
• Audited assets and liabilities, net delta, margin, venue and counterparty concentrations, legal seniority and realized losses become continuously independently verifiable
• Redemption terms, payout dependencies, gates and stressed-liquidity tests support the contemplated client position without manager-discretion ambiguity
• The fund changes to hold only short-duration government obligations and qualifies for an individual tokenized-Treasury review

The research file

Legal structure and access

USCC is a series of a Delaware statutory trust offered as a Section 3(c)(7) private fund under a Regulation D exemption. Investors hold restricted private-fund shares rather than a bank deposit or registered money-market fund. Access is limited to qualified purchasers in supported jurisdictions after entity, eligibility, AML and fund review; the stated minimum initial subscription is $100,000. Definitive offering documents, which are not public in the reviewed record, control over the website summary.

Portfolio and yield mechanism

Bitwise seeks cash-and-carry returns by combining crypto spot or staking assets with futures and other derivatives, alongside U.S. government securities. The 2026-08-15 product page reported $139.18M AUM, 2.40% trailing 30-day yield and a 0.75% management fee. Its dated holdings included cash collateral, USTB, staked SOL, weETH and XRP plus short or long futures at CME, Coinbase and FalconX. Those issuer-reported holdings were marked unaudited and can change at the investment manager’s discretion; they do not independently prove continuous delta neutrality.

Token and book-entry perimeter

USCC tokens on Ethereum, Plume and Solana and shares recorded in book entry are two representations of the same fund interest. Bitwise reported roughly 56% of share value in book entry on its July 2026 snapshot, which explains why onchain TVL materially understates total fund AUM. Token transfers are restricted to allowlisted holders. Superstate-administered contracts are upgradeable and include powers to mint, change allowlist status and forcibly burn tokens for legal circumstances; a token can initiate redemption but does not make the underlying basis portfolio onchain.

Control, custody and assurance

Bitwise Investment Manager assumed investment-management responsibility on June 1, 2026, while Superstate retained FundOS infrastructure, transfer-agency duties and a transitional sub-adviser role. The current product page names Anchorage Digital as custodian, NAV Fund Services as calculation agent and Ernst & Young as auditor. Superstate publishes audits for shared token and allowlist contracts. Those controls do not by themselves reconcile exchange margin, dealer marks, hedge execution, legal claims or every asset and liability at advisory-monitoring frequency.

Liquidity, redemption and loss path

An approved investor can request redemption of tokens or book-entry shares for USD or USDC. Superstate describes T+1 payment for requests before the 5 p.m. ET market-day cutoff and T+2 after it, subject to holidays. Bitwise states that USDC payout relies on Circle and is subject to fund-document restrictions; the fact sheet says the redemption program may be modified or terminated. During stress, proceeds therefore depend on manager action, NAV marks, collateral and hedge liquidity, custodian or venue access and payout rails, rather than an autonomous onchain reserve redemption.

Incident and evidence posture

No public USCC loss or incident ledger was identified in the controlling materials reviewed for this application, so the memo does not infer a clean incident record. The June 2026 manager transition and the decline from the launch announcement’s reported $259M AUM to the current $139.18M are observable operating changes, not proof of loss: flows, portfolio changes and valuation can all move AUM. Approval would require audited fund-level reconciliation, complete counterparty and margin evidence, transition controls, and an independently checked history of losses, gates and operational incidents.

Comparison and decision

A tokenized short-duration Treasury fund can be reviewed around identifiable government obligations, custody, valuation and redemption. USCC instead adds managed crypto spot, staking, derivatives, dealers and exchange access; its daily NAV and token wrapper do not remove those strategy and counterparty dependencies. The existing off-chain-credit and basis-trade dossier therefore decides. Reopen when full assets, liabilities, net delta, margin, venue and counterparty concentration, legal seniority, realized losses and liquidity tests are continuously and independently verifiable, or if the fund changes to Treasury-only holdings suitable for individual review.

Sources

The claims above trace to these. Where a number could not be independently verified, the thesis says so.

• Bitwise — USCC product, holdings and service providers · primary · accessed 2026-08-15
  Supports: total AUM, token and book-entry shares, portfolio holdings, manager discretion, service providers, qualified-purchaser access, USDC redemption risk
• Bitwise — USCC fact sheet · primary · accessed 2026-08-15
  Supports: cash-and-carry strategy, private-fund structure, management fee, daily liquidity, redemption-program modification
• Bitwise — investment-manager transition announcement · primary · accessed 2026-08-15
  Supports: June 2026 transition, Bitwise investment manager, Superstate FundOS, sub-adviser transition, prior AUM
• SEC EDGAR — USCC Form D/A · primary · accessed 2026-08-15
  Supports: Delaware trust series, 3(c)(7) private fund, Regulation D, Rule 506(c)
• Superstate Docs — Bitwise USCC mechanics and NAV · primary · accessed 2026-08-15
  Supports: basis positions, staking, government securities, NAV methodology, dealer marks, token and book-entry shares
• Superstate Docs — subscribing to tokenized funds · primary · accessed 2026-08-15
  Supports: token or book-entry issuance, allowlisted address, subscription instructions
• Superstate Docs — redeeming tokenized funds · primary · accessed 2026-08-15
  Supports: token redemption, book-entry redemption, USD and USDC payout
• Superstate Docs — token controls and audits · primary · accessed 2026-08-15
  Supports: upgradeability, allowlist, mint and forced burn, offchain redemption, shared contract audits
• DefiLlama — USCC onchain survey record, read 2026-08-15 · secondary · accessed 2026-08-15
  Supports: onchain TVL, token networks, basis-trading category, narrower survey perimeter

Inherited controls

The verdict above grades the protocol layer. Every position also inherits the asset it holds and the chain it settles on. The least safe layer sets the position’s grade, and the position table names which one that is.