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Tokenized real-world assets

WisdomTree 500 Digital ETF

Not approved The evidence weighs against it

Review open since 2026-09-26: Open item: Re-read the wisdomtree-500-digital-etf eligibility file: its issuer documents changed. A draft revision dated 2026-09-26 is under audit. The verdict stands until the review closes.

Verdict
Not approved
The evidence weighs against it
Who can freeze it
No freeze key
Withdrawals
The prospectus sets no investor minimum.
Reviewed
2026-10-18
Researched memo

Summary

Ketju does not approve the WisdomTree 500 Digital ETF because the fund does not exist yet: its registration is not effective, and no shares have been sold. WisdomTree filed the prospectus on 12 May 2026 with the ticker, listing exchange, sub-adviser and fee left blank. It has pushed the effective date back three times, most recently on 18 September 2026 to 18 October 2026. The proposed fund would track the WisdomTree 500 Index, the 500 largest US-listed companies weighted by market capitalization with a 10% cap per name. It is a series of WisdomTree Digital Trust, the registered investment company that already issues WTGXX. The trust would issue each share in one of two forms. A DTCC share is held through a broker like any ETF. A Tokenized Share is recorded on a blockchain, and WisdomTree Transfers, the trust’s digital transfer agent, keeps its official register. The two forms carry the same vote and the same dividend, and a holder may switch between them. WisdomTree has published no contract address. Ketju will review the fund again when the registration goes effective, the shares list, and WisdomTree publishes the token contracts.

Changes

2026-10-18The memo’s first sentence said Ketju does not approve the WisdomTree 500 Digital ETF, but the Register showed Under review. The fund’s registration is not effective and no shares have been sold, and that fact does not wait on missing evidence. Ketju changed the verdict to Not approved. The reasons and the review triggers did not change. The prior memo

Research

How it works

Post-Effective Amendment No. 95 to the trust’s Form N-1A, filed 12 May 2026, adds the WisdomTree 500 Digital ETF. It is a passive fund that seeks to track the WisdomTree 500 Index before fees, using representative sampling and holding at least 80% of net assets in index constituents. WisdomTree, Inc. keeps the index. It holds the 500 largest companies domiciled and listed in the United States that pass a $100 million market-cap screen and a $200,000 average daily volume screen. WisdomTree reconstitutes it once a year, caps single names at 10%, and caps the combined weight of names above 5% at 40%. WisdomTree Digital Management is the adviser. The filing leaves the sub-adviser, the management fee, the other expenses, the ticker, and the listing exchange as bracketed blanks. The fund will not hold any digital asset. The fund pays dividends, if any, quarterly in US dollars, and capital gains once a year.

The prospectus states that the trust issues a share in one of two recording formats. DTCC Shares sit in book entry at the Depository Trust Company in Cede’s name on the books of The Bank of New York Mellon, the fund’s transfer agent, and trade on the listing exchange through brokers. Tokenized Shares are recorded on a blockchain. WisdomTree Transfers, Inc., the digital transfer agent, keeps them in a master securityholder file that stores token quantity and wallet address on chain and the holder’s identity off chain. The SAI says each Tokenized Share “is a digital representation of one share of the Fund recorded on a blockchain” and that the two forms “are fungible with one another and represent the same class of shares.” Both carry one vote per share and the same distributions. A holder may switch formats by filing a transfer form with WisdomTree Transfers. A switch from token to DTCC burns the token and credits the share to DTC’s account at BNY, and the reverse mints a token into an approved wallet. The SAI says a switch “may take multiple business days.” The prospectus warns that a token holder who wants to sell on the exchange would have to wait that long.

Who controls it

WisdomTree Transfers reconciles its book-entry register against the chain at least daily, and its book-entry record “constitute[s] the official record of ownership for Tokenized Shares.” WisdomTree Transfers treats the chain as a source of information and keeps the register itself. A peer-to-peer transfer “would not be legally valid until registered by WisdomTree Transfers.” Until WisdomTree Transfers registers it, the transferee is not a shareholder of record for dividends or votes. Above WisdomTree Transfers sits BNY, which keeps the fund’s overall share count. BNY reconciles that count each business day against the total WisdomTree Transfers reports. If the two cannot be reconciled after investigation, “the records maintained by BNY shall control.” WisdomTree Transfers then carries the adjustment into its books and the chain. Where the chain and WisdomTree Transfers disagree, WisdomTree Transfers corrects the chain with a later transaction.

A WisdomTree affiliate builds the smart contracts under WisdomTree Transfers’ oversight. The contracts block transfers to or from unregistered wallets, and WisdomTree Transfers can use them to claw back tokens that do not match the book. WTGXX uses the same control model. Ketju read the WTGXX Ethereum contract in September 2026 and found role-gated mint, freeze, clawback, pause, and a beacon upgrade. The SAI also describes conditional registration. WisdomTree Transfers may record an authorized participant as a pending owner, and mint a token, before the fund strikes NAV and settlement completes. The position “may be adjusted or reversed.”

Eligibility and withdrawals

The prospectus sets no investor minimum. Brokers buy and sell DTCC Shares at market prices. A Tokenized Share requires a wallet that WisdomTree Transfers has registered “in its sole discretion.” WisdomTree Transfers first collects name, address, date of birth, and documents under its customer identification program. Tokenized Shares change hands through broker-dealers “which may include WisdomTree Securities,” the trust’s own distributor, in bilateral principal trades at prices the dealer sets. The prospectus concedes that “the only venue to purchase or sell Tokenized Shares may be via WisdomTree Securities.” It also says that tokens held outside a SIPC member account have no SIPC protection, and that no dealer may be willing to make a market. Holders may transfer between whitelisted wallets at any price, and the fund plays no part in matching buyers and sellers.

No ordinary holder can redeem a share. Only authorized participants redeem, in Creation Unit Aggregations, for a basket of securities or cash. A retail holder sells to a dealer or to another whitelisted wallet, or switches to DTCC form and sells on the exchange.

Registration

WisdomTree filed the amendment under Rule 485(a)(2) to go effective 75 days later, on 26 July 2026. WisdomTree then filed three amendments under Rule 485(b)(1)(iii), each with “the sole purpose” of delaying effectiveness: on 24 July to 23 August, on 21 August to 20 September, and on 18 September to 18 October 2026. The exhibits list filed with the amendment marks six documents as “to be filed by amendment.” They are the schedule adding the fund to the trust instrument, the advisory appendix, the distribution appendix, the custody appendix, the WisdomTree Transfers appendix, and the BNY transfer agency agreement. As of 25 September 2026 the fund has no ticker, no listing exchange, no named sub-adviser, no fee, no contract address, and no sales. WisdomTree’s own site returns no page for it.

The filing names different chains for holder wallets in different places. The summary and risk sections name Stellar and Ethereum. The buying-and-selling section lists Arbitrum, Avalanche, Base, Ethereum, Optimism, Solana, and Plume, and the SAI describes Stellar’s consensus at length. The documents do not show which chains will go live.

Comparison

We compare the fund with WTGXX, the trust’s money-market fund already in the Register. We also compare it with the DTC Tokenization Service, which puts existing S&P 500 ETFs such as SPY on chain under the same CUSIP. This fund would be a registered ’40 Act index ETF whose transfer agent keeps the official register, and its exchange listing would give a holder a second way to sell. Of the structures in this group, Ketju regards that one as the strongest. But Ketju can judge only a fund that exists. The registration is not effective, WisdomTree has not sold any shares, and the filing leaves blank the terms that matter to an advisor: the fee, the ticker, the exchange, the chains and the contracts. We do not approve the fund for that reason. The file holds the issuer’s words as filed, so Ketju can review the fund the day it goes live. Ketju will review it again on the effective date, the listing, and a published contract.

Sources

Each claim above comes from one of these sources. Where Ketju could not verify a number, the memo states that.

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.

ChainVerdictFreezeWhat it can do
EthereumApproved No freeze key Ethereum has no sequencer, no upgrade key and no operator who can be compelled to act; rule changes require social consensus.
StellarNot approved Issuer can freeze freeze is native at every level: issuers hold revocation and clawback flags on their assets, and since Protocol 26 the validator quorum can vote to freeze specific accounts and trustlines on-chain (CAP-77).
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