Coinbase USD Stablecoin Yield Fund (CUSHY)
Summary
Ketju does not approve CUSHY: the fund lends to crypto borrowers and buys credit that a reader cannot inspect, returns money once a quarter, and has two investors, and only qualified purchasers may buy it. CUSHY is a share of Coinbase Tokenized Stablecoin Yield Feeder Fund Ltd, a Cayman company that Coinbase Asset Management runs to lend stablecoins and buy credit. It targets SOFR plus 4 to 7 percentage points. Superstate’s page showed a 30-day yield of 7.54%. Superstate is transfer agent and issues the token on Solana and Base. The fund charges 0.75% a year plus 10% of returns. The Form D, filed on 23 June 2026, reports $25 million sold to two investors. The token adds allowlisted transfers between wallets but no earlier redemption.
- Coinbase Asset Management or Superstate publishes the offering memorandum and it changes the investor class, fees, or redemption terms
- The fund opens to accredited investors under section 3(c)(1)
- The fund gates or delays a quarterly redemption, or a borrower default cuts NAV
- The Solana mint authority or the Base owner key moves to a multisig with a delay
Ketju checks this memo every night and opens a review if its venues or files show a warning or a cited document changes. The first confirmation is due 2026-12-24.
Research
How it works
Superstate’s documentation says CUSHY “seeks to generate yield from high-quality stablecoin private credit, direct lending, and tokenized credit opportunities.” It names three areas: liquid public credit; senior secured, direct lending and asset-backed finance; and opportunistic credit. The target is SOFR plus 400 to 700 basis points or more, and Superstate’s page calls that target hypothetical. NAV started at $100, and the fund strikes it monthly; it stood at $100.989261. Coinbase Custody Trust Company and other qualified custodians hold the assets. Northern Trust administers the fund, and Deloitte audits it. Coinbase Asset Management’s own fund page sits behind an investor-status gate and names the product “Coinbase Stablecoin Credit Fund.” We did not read its memorandum.
Fees
The tokenized Share Class T pays a 0.75% management fee, against 1.25% for the standard Class A. It also pays a 10% performance fee and custody and administration costs.
Eligibility
The Form D claims Rule 506(c) and the Investment Company Act section 3(c)(7) exclusion, so only qualified purchasers may buy. Superstate lists eligible investors as “US UBO, Qualified Purchasers, Non-US UBOs qualified per their jurisdiction.” The section 3(c)(7) claim sets the US minimum standard at qualified purchaser. The gate on Coinbase’s site also mentions accredited investors, which section 3(c)(7) does not allow on its own. Investors onboard with Superstate, Northern Trust and Coinbase Asset Management. The minimum initial investment is $100,000, which the manager may raise, lower or waive. Household clients who are not qualified purchasers do not qualify.
Withdrawals
Subscriptions are monthly. Shares arrive on the dealing day after the month of the order, as tokens in an allowlisted wallet or as book-entry shares. Tokens move only between allowlisted wallets. Redemptions are quarterly: the fund pays proceeds “on the Redemption Dealing Day for requests received in the previous calendar quarter.” One sentence of the same documentation says liquidity is offered “at monthly end.” The fund page and the redemption section both say quarterly.
Who controls it
On Solana, CUSHY is a Token-2022 mint. New accounts start frozen until the allowlist unfreezes them. The freeze authority and the permanent delegate, which can move or burn any holder’s tokens, are one program address, 2Yq4…pM7x. The same address holds those powers over Superstate’s USTB. The mint authority is a single key, 7gF8…xAHF.
On Base, CUSHY is Superstate’s upgradeable fund token. A single key, 0xb6c7…1731, owns it and can mint, pause and burn from any holder. A proxy admin contract controls upgrades, and a separate single key owns the allowlist. Superstate states that its admin address controls “all minting, adding or removing users from the allowlist, and forcibly burning an investor’s tokens.”
Size and holdings
On 24 September 2026 Superstate’s page showed $25,247,315 in assets, 240,000 tokens on Solana, 10,000 on Base and 19,804.14 book-entry shares. At the stated NAV, those shares are worth about $27.2 million, $2 million more than the stated assets. The page does not explain the gap. Two wallets hold the Solana tokens, with 140,000 and 100,000, and one wallet holds the Base tokens. These holdings match the Form D, which reports $25 million from two investors and a first sale on 11 June. Superstate names itself transfer agent but does not say whether its books or the chain govern ownership.
Comparison
The fund earns its spread by lending to borrowers in the crypto economy and by buying credit that a reader cannot inspect. It pays that spread out through a quarterly window. A qualified purchaser could compare it with a tokenized Treasury fund on the same platform, such as USTB. That purchaser would give up daily redemption and government credit for about four to seven points of hoped-for spread and a 10% performance fee. The fund has two investors and three months of history. Its history cannot yet show how the fund behaves when a borrower fails.
Sources
Each claim above comes from one of these sources. Where Ketju could not verify a number, the memo states that.
- Superstate: CUSHY, Coinbase USD Stablecoin Yield Fund (fund page) · primary · accessed 2026-09-24
Supports: $25.2M AUM, NAV $100.989261, 7.54% 30-day yield, eligible investors, quarterly redemption, fees, service providers, token counts by chain - Superstate docs: Coinbase CUSHY · primary · accessed 2026-09-24
Supports: strategy, $100,000 minimum, allowlisted transfers, quarterly redemption dealing, monthly-end liquidity sentence - Superstate docs: Smart contracts · primary · accessed 2026-09-24
Supports: admin mints, allowlists, and burns, upgradeable contracts - SEC EDGAR: Coinbase Tokenized Stablecoin Yield Feeder Fund Ltd, Form D (2026-06-23) · primary · accessed 2026-09-24
Supports: Cayman exempted company, Rule 506(c), section 3(c)(7), $100,000 minimum, waivable, 2 investors, $25M sold, first sale 2026-06-11 - Coinbase Asset Management: CUSHY details (investor-status gate; fund data behind it not read) · primary · accessed 2026-09-24
Supports: Coinbase Stablecoin Credit Fund name, accredited and qualified purchaser gate - CoinDesk: Coinbase’s asset manager to offer stablecoin credit fund with tokenized share class (2026-04-30) · secondary · accessed 2026-09-24
Supports: announcement, Superstate FundOS, Solana, Ethereum, Base
The asset and the chain
This memo covers the protocol. A position also holds an asset and settles on a chain. Whichever of the three holds the most power over the position decides who can freeze it. These tables describe control and do not judge quality.
| Chain | Verdict | Freeze | What it can do |
|---|---|---|---|
| Solana | Approved with limits | Governed, no freeze | no admin key can seize funds, but stake is concentrating and the Nakamoto coefficient is below 25. |
| Base | Approved with limits | Mixed control | Coinbase, one regulated US company, operates the only sequencer, and admin keys can upgrade bridge contracts within about 7 days. |