Coinbase USD Stablecoin Yield Fund (CUSHY)

Research, firm shelf, model-client eligibility, and advisor selection are recorded separately. The scheduled date is the outside bound; new evidence can reopen the file sooner.

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 and showed a 30-day yield of 7.54% on Superstate’s page. Superstate is transfer agent and issues the token on Solana and Base. The Form D, filed 23 June 2026, reports $25 million sold to two investors, and two Solana wallets hold 240,000 of the 250,000 tokens. The Form D claims Rule 506(c) and the Investment Company Act section 3(c)(7) exclusion, so only qualified purchasers may buy. The minimum is $100,000, which the manager may raise, lower, or waive. Subscriptions are monthly and redemptions quarterly: a request made in one calendar quarter is paid on a dealing day in the next. The assessment is adverse. Model clients are not qualified purchasers. For one who is, CUSHY pays a spread for lending to crypto borrowers, charges 0.75% plus 10% of returns, returns money once a quarter, and has two holders; the token adds allowlisted transfers, not an earlier exit.

Research triggers: events that reopen the assessment or shelf decision
• 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

The research file

What the fund holds and charges

Superstate’s documentation says CUSHY “seeks to generate yield from high-quality stablecoin private credit, direct lending, and tokenized credit opportunities,” in 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 the page says that target is hypothetical. The tokenized Share Class T pays a 0.75% management fee against 1.25% for the standard Class A, plus a 10% performance fee and custody and administration costs. NAV started at $100 and is struck monthly; it stood at $100.989261. Coinbase Custody Trust Company and other qualified custodians hold assets, Northern Trust administers the fund, and Deloitte audits it. Coinbase Asset Management’s own fund page is behind an investor-status gate and names the product “Coinbase Stablecoin Credit Fund”; its memorandum was not read.

Who may hold, and how money gets out

Superstate lists eligible investors as “US UBO, Qualified Purchasers, Non-US UBOs qualified per their jurisdiction.” The Form D’s section 3(c)(7) claim settles the US floor at qualified purchaser; the gate on Coinbase’s site mentions accredited investors too, which 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. Shares arrive on the dealing day after the month of the order, as tokens on an allowlisted wallet or as book-entry shares, and move only between allowlisted wallets. Redemption proceeds come “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 say quarterly.

Who controls the token

On Solana CUSHY is a Token-2022 mint. New accounts start frozen until the allowlist thaws 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 one that 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.”

The record against the filings

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. The Solana tokens sit in two wallets holding 140,000 and 100,000, and the Base tokens in one. The Form D’s $25 million from two investors, first sold 11 June, matches that record. Superstate names itself transfer agent but does not say whether its books or the chain govern.

Comparison and decision

The fund earns its spread by lending to borrowers in the crypto economy and buying credit a reader cannot inspect, and pays it out through a quarterly window. A qualified purchaser weighing it against a tokenized Treasury fund on the same platform, such as USTB, gives up daily exit and government credit for about four to seven points of hoped-for spread and a 10% performance fee. With two investors and three months of history, the record cannot yet show how the fund behaves when a borrower fails. The assessment is adverse; the program stays research-only, and it is ineligible for model clients because they are not qualified purchasers.

Sources

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

• 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

Inherited controls

The research above describes the protocol layer. Every position also inherits the asset it holds and the chain it settles on. The most administered layer sets the position’s effective control grade; that is a control description, not a quality or suitability score.