• Is CLARITY Kaput?
• Morgan Stanley Goes All In: Files for BTC, SOL, ETH; Plans Wallet
• Bitwise in Beast Mode: Launches CLNK, BPRO; Posts 11 'Strategy' Filings

Opacity

The CLARITY Act car crash does have some positive interpretations, at the margin, albeit none worth the looming risk of the legislation being entirely scuppered, or finalization being pushed forward by multiple months. For one, if this doesn't kill it, it will indeed be stronger – should protagonists somehow manage to integrate a wider range of the multivalent demands that have come to light in recent days. Secondly, even with Bitcoin barely treading water around the the $90k handle again, the main discourse has moved away from prices. Perhaps only a temporary break from the exclusive fixation of a still too-large cohort of participants, but a welcome one... combined with a broadening awareness that this is how law making is often done.

The latest is that hopes of a resumption of movement on the delayed markup from the Senate Banking Committee have been dashed again; Coindesk says "indefinitely postponed".

Somewhat more positively, Senate Banking may simply be out of time for now, as its members pivot to consideration of possible housing legislation the White House has signaled is a priority. If that's the key driver of fading Senate Banking attention then, again, while not an ideal state, circling back is on the cards, by default.

Less positively, Senate Agriculture's markup remains scheduled for next week, with no chance of Democrat support, almost certainly sealing that draft's fate as a dead end.

Meanwhile, in continuing fallout from the thumbs down by Coinbase CEO Brian Armstrong, which is widely perceived to have triggered the derailment of the process, the White House has this week waded in with harsher-edged reprimands. These could of course have the opposite of (presumably) the desired effect of focusing minds, by hardening positions instead.

Our read-through of the CLARITY Act, the bust up, and assessment of the bill's chances, is excerpted below.

• In much more positive news for the institutional space, Morgan Stanley is set to become the first 'white shoe' institution to launch a spot Bitcoin ETF. And two others cryptocurrency ETFs. And a crypto wallet. (All ETFs to be based on CF Benchmarks's regulated index methodology.) Details and high-level implications further down.
• As well, the impact of that tidal wave of filings the SEC faced at the end of last year is starting to show on Wall Street, with a trickle of new funds that's set to become a flood as the weeks and months pass.
• We focus chiefly on new funds from Bitwise below, as the $15 billion AuM firm switches into high gear, while replenishing more of the SEC's crypto ETF review pipeline with fresh filings, than it's trimming with listings.
• Plus, Nasdaq Crypto Index (NCI™) becomes Nasdaq CME Crypto™ Index (NCI™️).
• And, more event contract pricing enters CF Benchmarks' safeguarded liquidity complex, as Interactive Brokers' prediction platform pivots to CFB Real-Time indices for crypto settlement.

Where Next for the CLARITY Act After a Week That Left it On the Brink?

Understanding the CLARITY bill's Senate rewrite, and how to keep tabs on the “market structure” narrative that could impact listed crypto products.

A Week of Unclarity

How worried should we be about the latest developments surrounding the CLARITY Act, amid a crypto-native backlash that calls the updated proposals “regulatory capture”?

Recent twists and turns in the progress of the Digital Asset Market Clarity (CLARITY) Act have turned what was already a complex policy process into something even seasoned market participants may struggle to keep track of: multiple committees, overlapping drafts, fast-moving amendments, and media shorthand that blurs distinct legislative texts.

Not to mention that, in fact, the overarching process comprises of separate House and Senate “market structure” efforts.

Here, we will get caught up on where things stand for ‘CLARITY’ after last week’s rancor. We’ll also unpick the differences between the currently bifurcated House and Senate proposals, before explaining how they’re expected to converge in practice.

What’s driving the controversy?

First, a quick summary of how we got here – ‘here’ being a stalemate on Capitol Hill after some of highest profile voices in the space gave the current incarnation of the CLARITY Act an unequivocal thumbs down.

Even without adjudicating every claim, it's clear objections are clustering around: (1) economic rights (what activities are permitted), (2) regulatory perimeter (which venues fall in-scope), and (3) agency balance (SEC vs CFTC).

These themes overlay three major points of contention:

• Stablecoin rewards / yield-like features.
  How stablecoin ‘rewards’ – more specifically yield limits – will be finessed - if yields are permitted at all, is one of the most concrete issues, with banks arguing the structure could accelerate deposit flight, while crypto firms argue restrictions are anticompetitive.
• Tokenized equities / tokenized real-world assets (RWAs).
  The concern that draft language could function as a de facto constraint on tokenized equities has been among the most directly cited criticisms to have emerged following the most recent Senate episode.
• DeFi scope and privacy.
  Claims that the evolving drafts could expand obligations in ways that are incompatible with open-source, non-custodial (decentralized) architectures—is one reason for the continued widespread “control vs permissionless” framing.

When Two Bills Collide

When an already potentially controversial bill enters the legislative process in one house, and then discussion proceeds to the other, this is an inevitable, classic – and perhaps even necessary – recipe for disputes. Those who could use a micro-recap of the CLARITY bill and clear attributions of key pillars to the branch of their origin, read on below.

The ‘Original’ CLARITY Act

The House version is H.R. 3633, the Digital Asset Market Clarity Act of 2025, introduced May 29th, 2025, and designed to establish a federal framework for “digital commodities” and related intermediaries. The House passed it on July 17, 2025, by 294–134.

The Senate’s ‘CLARITY Act’

In parallel, the Senate Banking Committee has been driving its own market-structure text—commonly referred to as the “Responsible Financial Innovation Act of 2025” in discussion-draft form—covering issues under the committee’s jurisdiction – i.e., its SEC-facing architecture. (Here’s Jones Day’s concise summary from September.)

Product Momentum: Morgan Stanley Joins Single-Asset Queue, Nasdaq x CME Refresh NCI, Bitwise Lists CLNK

The early 2026 regulated-products tape reinforces a pattern we’ve been tracking across 2025–26

What a Huge Wall of Filings Tells us about the Next Wave of US Crypto ETFs - CFB

What a Huge Wall of Filings Tells us about the Next Wave of US Crypto ETFs - CFB

CFBKen Odeluga

Listings and filings have continued to coalesce around similar themes:

• Distribution is still converging on familiar, governance-focused reference points
• At the margin, issuers are experimenting with new spot underlyings (see, LINK, SUI)
• From the allocator perspective, salient emergent threads include distinct packaging, permissioning, and operational de-risking
• Meanwhile, adjacently, the influence of the dominant listed crypto product, IBIT, continues to expand beyond its domicile, with the launch of another feeder

A selection of recent product filings and launches referencing regulated CF Benchmarks indices follows.

Morgan Stanley Files for BTC, SOL, ETH + Staking

After several infamously protracted and studious years on the sidelines, Morgan Stanley has—effectively—publicly signaled capitulation, with a clutch of ETF registrations.

On January 6th the group tabled S-1s for funds investing in spot Bitcoin, Ether and Solana, proposing to integrate CF Benchmarks’ BBRNY, SOLUSD_NY, and ETHUSD_NY indices into the respective vehicles for NAV calculation.

The Ethereum product filing notably includes a staking component. This makes Morgan Stanley’s first direct push into the issuer lane, as that stands today, fully comprehensive and contemporaneous – i.e., no further circumspection is planned.

The group’s transition from its prior mode as mere distributor of third-party crypto ETPs is thus complete. Latent synergies from being the operator of one of the largest and most influential wealth management franchises globally (via Eaton Vance, E*TRADE, et al) should now be within reach.

High-Level Signals

• Distribution ‘greenlight’: Morgan Stanley’s wealth management-led franchise stepping in as an issuer is an incremental legitimization vector: it helps negate one tacit frame that prevails among certain platforms and advisors, which goes something like this: crypto ETPs may be ‘allowed’, but they’re not yet ‘endorsed.’ Now, they are.
• Benchmark standardization: That the heft of dominant asset managers like BlackRock has led Wall Street’s implementation of crypto ETFs is not in question. However, Morgan Stanley is set to become the first ‘white shoe’ firm to list a crypto ETP. This matters almost axiomatically for pathways that other ‘bulge bracket’ and ‘Big 4’ peers will follow.
• Benchmark liquidity: This is of course critical for ease of replication; and replication is critical for efficiency. The liquidity and replicability of our Bitcoin, Ether and SOL benchmarks, among others, has quickly become self-reinforcing and compounding, which in turn steers ever more critical participants (market makers, etc.) towards these benchmarks, often irrefutably—if offered the choice.
• ETH staking: This component might well evolve, depending on the direction the SEC may decide to nudge the application in. Either way, again, the presence of staking suggests it's becoming table stakes for this issuer cohort, meaning they’re already competing on structure, not just on which underlyings to wrap.
• Wallet Plans
  Adjacently, Morgan Stanley also indicated plans for a proprietary digital wallet, penciling in H2 2026 as a possible launch window, alongside expanded crypto trading ambitions on E*TRADE. This all suggests the firm is thinking beyond product shelf-space and looking toward a fuller-stack digital-asset offering.

Bitwise, 21 Shares Target Alt Demand

Meanwhile, regardless of whether the crypto price environment should be interpreted as tentatively recuperating, or on a pause before another down leg, high-profile issuers are still assuredly floating fresh inventory.

As we’ve seen, much of this momentum largely comes down to considerable pipeline pressure. Nevertheless, the stream of activity provides a degree of backing for expectations of continuing demand. Notable launches and filings are outlined below.

Bitwise lists CLNK, ‘Debasement’, files SUI

With a flurry of ETP projects either formally kicked-off (i.e., filings) or coming to fruition (launches) across late December and early 2026, Bitwise is in asset expansion mode.

Applications notably include several ’40 Act ‘strategy’ ETF filings, leaning heavily on derivatives-based structures, plus at least one ‘exposure innovation’.

The headline launch was the Bitwise Chainlink ETF (CLNK) listed on NYSE Arca, providing spot exposure to LINK by tracking the CME CF Chainlink-Dollar Reference Rate - New York Variant (LINKUSD_NY).

It's predicated on what Bitwise CIO Matt Hougan calls LINK’s status as one of the “least understood” and “undervalued” protocols, plus its dominant position within ‘middleware’, which Hougan suggests has largely been eclipsed by its best-known role as oracle infrastructure.

I think of Chainlink as a software platform business. Specifically, it’s a high-growth software platform with a dominant market share in a very large and fast-growing market.

Matt Hougan, from ‘Why I Love Chainlink’, in The Weekly CIO Memo

De-Based

Bitwise this week followed single-asset focused CLNK with the launch of the much more nuanced, thematic and multi-asset based Bitwise Proficio Currency Debasement ETF (NYSE: BPRO). Landing, likely by design, amid a garrulous investor conversation on (currency) ‘debasement’, BPRO looks capable of appealing to more recent digital asset entrants and crypto natives alike, with the latter having tilted towards anti-debasement strategies for far longer.

Whilst the subject of much debate, the idea of ‘debasement’ protection typically references investment in Bitcoin, so BPRO unsurprisingly includes BTC exposure via the fifth largest Bitcoin ETF by AuM, Bitwise Bitcoin ETF (BITB), the NAV of which is based on BRRNY.

Given a mandate to offer combined “exposure to Bitcoin, gold, miners, and precious metals” though, BPRO is also a portfolio of several other ETFs, including funds backed by investments in gold, silver, U.S. Treasurys, and T-Bills; plus 3 further BTC funds – with IBIT (another BRRNY-tracker) the largest crypto weight at launch (6.12%).

Overall, BPRO is in keeping with signs we spotlit in our year-end crypto ETF ‘state of play’ review, here. A move by sponsors to more flexible crypto offerings, particularly regarding exposure, as crypto-focused firms expand strategies to meet mainstream demand where it lies: integrated within holistic objectives.

Sui Filing

Meanwhile, Bitwise is keeping up the flow of new ETF paperwork, as the group, together with peers, pushes further down the size, visibility and demand tiers. It’s filing for a spot Bitwise Sui ETF cites CME CF Sui-Dollar Reference Rate - New York Variant (SUIUSD_NY) for NAV.

Another theme we've mentioned recently is a rise in the more customizable ’40 Act framework.

With a December 30th filing covering no fewer 11 than “Strategy” ’40 Act ETFs, Bitwise is leaning heavily into the trend. All offering single-asset exposure, the funds cover some protocols the firm already offers within spot-based vehicles, and some which are entirely novel for the firm, e.g., Zcash (ZEC), Ethena (ENA), Hyperliquid (HYPE), Starknet (STARK) and others.

TDOG Listing

Likewise, this week also saw the launch of the 21shares Dogecoin ETF (TDOG), which seeks to track DOGE as measured by the CF Dogecoin-Dollar US Settlement Price (DOGEUSD_NY).

Following the singular ‘meme coin’ narrative of its earlier years, issuers like 21 Shares have latterly been zeroing in on DOGE's high-speed, low-cost transaction architecture, its potential as a PoW, L1 protocol, and the ‘gateway’ effects of cultural origins.

We can place much of the recent batch of filings in the category ‘optionality’ tests of the eligibility frontier; where many firms are planting experimental flags.

Meanwhile, use of the ’40 Act structure is consistent with the realization that it potentially offers a smoother path to ‘effective’ status, and that the framework can turbo charge a filing’s chances in this post-Generic Listing Standards climate.

Nasdaq CME Crypto Index (Re)launch

Nasdaq and CME Group have announced a deepening of their 30-year partnership with the relaunch of the Nasdaq Crypto Index (NCI™) as the Nasdaq CME Crypto™ Index (NCI™️).

Initially launched in 2021 the gauge is part of an ecosystem of digital asset indices that has since grown to 20 benchmarks, covering seven individual digital assets, while also including four NCI^TM variants.

Several of these indices have been licensed for products issued by crypto-native asset manager Hashdex across the U.S., Europe, and Latin America; supporting more than $1 billion in assets today, including the first U.S. crypto portfolio ETF, then known as the Hashdex Nasdaq Crypto Index US ETF (ticker: NCIQ), and since renamed the Hashdex Nasdaq CME Crypto Index ETF.

CF Benchmarks serves as the Calculation Agent for all Nasdaq Series Crypto Index Family indices, while Nasdaq is the Benchmark Administrator.

“This is not just a name change,” said Giovanni Vicioso, Executive Director of Equity and Alternative Products at CME Group. “It is the combination of two gold standards to deliver the regulated diversification and foundational building block the market now demands.”

“We see the index-based approach as the direction investors are heading, beyond just bitcoin,” said Sean Wasserman, CFA, Head of Index Product Management at Nasdaq. “That’s similar to what we’ve seen in other asset classes, where you have indexes that are representative of the broader market.”

With filings for crypto basket ETFs as the second-highest category of live applications under review by the SEC at the end of last year, this refreshed Nasdaq-CME digital asset collaboration, with a particular tilt toward increased multi-asset index interest, is timely.

Interactive Brokers' ForecastEx Pivots to CFB Indices

ForecastEx is the latest regulated provider of event contracts—AKA regulated prediction markets—to deploy CF Benchmarks indices for crypto settlement.

The CFTC-registered Designated Contract Market (DCM) and Derivatives Clearing Organization (DCO) – a wholly-owned subsidiary of Interactive Brokers – has begun the process of transitioning to CFB’s UK FCA regulated Real-Time Index (RTI) methodology for settlement references of its suite of crypto price contracts.

First BTC, ETH, SOL

Initial coverage of RTI-settled forecast contracts will encompass BTC, ETH, SOL, XRP, and DOGE prices, with the respective streaming CFB indices being BRTI, ETHUSD_RTI, SOLUSD_RTI, XRPUSD_RTI, DOGEUSD_RTI. ForecastEx plans to eventually roll-out CFB RTIs across the full suite of its crypto price products, bringing the same price representativeness, replicability and resistance to manipulation as integrated into crypto products offered by Kalshi, the largest regulated prediction market operator, which also utilizes CFB indices.

Insto Prediction Markets

As we set out in our December examination of the event contract market, it is in fact a regulated subset of white-hot prediction trading.

Kalshi Leads Surging Crypto Event Contract Market, Powered by CF Benchmarks - CFB

Kalshi Leads Surging Crypto Event Contract Market, Powered by CF Benchmarks - CFB

CFBKen Odeluga

With institutions showing interest in the granular pricing and behavior data generated by such venues, benchmark-led settlement design is a gating factor for suitability.

ForecastEx’s integration into the Interactive Brokers platform, much like Robinhood’s outsourcing of prediction trading to Kalshi, brings ‘Forecast Contracts’ into a high-intent, highly informed environment made for serious traders, which is quite likely to prove fertile ground for ‘information venue’ effects.

IBIT’s Footprint Expands to Brazil

Galapagos Capital, a Brazilian asset manager, is among the most recent firms to launch a ‘feeder fund’ investing in BlackRock’s iShares Bitcoin Trust ETF (IBIT) the largest spot Bitcoin fund.

São Paulo-Headquartered Galapagos, which currently cites AuM at $4.2 billion, launched GBIT11 in December, joining several other Bitcoin ETFs on Brazil’s B3 exchange.

Just as notably, GBIT11 is the latest in a growing number of funds listed offshore to the U.S. providing Bitcoin exposure via IBIT.

Two IBIT-tied vehicles sponsored by iShares subsidiaries are currently available overseas; one launched in Canada, in March 2025, and another in Australia, last November.

As such, GBIT11 appears to be the first master/feeder-structured IBIT ETF sponsored by an unaffiliated entity. (Though Galapagos’ Head of ETFs is a former BlackRock executive, according to Brazil’s Valor.)

Either way, IBIT’s massive footprint is continuing to expand outside of its own border, notionally providing liquidity, visibility and other benefits to participants, including investors.