Bitwise Chainlink ETF Files S-1/A, Waives Fees for First Month

TL;DR

**Bitwise is launching a Chainlink ETF (CLNK) with a fee waiver, making it a compelling early play for crypto exposure if the SEC greenlights it.**

AI Summary

The Bitwise Chainlink ETF (CLNK) filed an S-1/A on November 18, 2025, to offer an exchange-traded product providing exposure to Chainlink, less operational expenses. The Trust will hold Chainlink and use the CME CF Chainlink–Dollar Reference Rate – New York Variant as its pricing benchmark. Bitwise Investment Advisers, LLC serves as the Sponsor, implementing a unitary management fee of 0.34% per annum, with a full waiver on the first $500 million of Trust assets for the initial month post-listing. Coinbase Custody Trust Company, LLC is the Chainlink Custodian, responsible for secure safekeeping in segregated accounts. While not currently engaged in staking, the Trust intends to amend its registration statement to include staking as a secondary investment objective, seeking to derive additional Chainlink. Bitwise Asset Management, Inc. provided $200 in seed capital on October 22, 2025, purchasing 8 Shares at $25 each, forming the basis for the audit. Bitwise Investment Manager, LLC is expected to purchase initial Baskets totaling 100,000 Shares for $2,500,000 at $25 per share, with proceeds used to acquire Chainlink prior to listing on NYSE Arca, Inc. The filing highlights significant risks associated with direct Chainlink investment and the speculative nature of the securities.

Why It Matters

This S-1/A filing signals Bitwise's intent to launch a Chainlink ETF, offering investors a regulated and accessible avenue to gain exposure to the LINK cryptocurrency without direct ownership complexities. The 0.34% management fee, with an initial 1-month waiver on the first $500 million, could attract significant early capital, intensifying competition in the nascent crypto ETF market against other digital asset offerings. For employees, this expands Bitwise's product suite and market footprint, while customers gain a new investment vehicle. The broader market will watch for SEC approval, which could set a precedent for future decentralized finance (DeFi) related ETFs, impacting Chainlink's price and adoption.

Risk Assessment

Risk Level: high — The filing explicitly states, "AN INVESTMENT IN THE TRUST MAY NOT BE SUITABLE FOR INVESTORS THAT ARE NOT IN A POSITION TO ACCEPT MORE RISK THAN MAY BE INVOLVED WITH OTHER EXCHANGE-TRADED PRODUCTS THAT DO NOT HOLD CHAINLINK OR INTERESTS RELATED TO CHAINLINK. THE SHARES ARE SPECULATIVE SECURITIES. THEIR PURCHASE INVOLVES A HIGH DEGREE OF RISK AND YOU COULD LOSE YOUR ENTIRE INVESTMENT." This direct warning, coupled with the inherent volatility of digital assets like Chainlink, indicates a high risk level.

Analyst Insight

Investors should closely monitor the SEC's approval process for CLNK and evaluate the competitive landscape of crypto ETFs. Consider the 0.34% management fee and the initial fee waiver against other potential offerings, but be prepared for significant volatility given the speculative nature of Chainlink as highlighted in the filing.

Key Numbers

• 0.34% — Unitary management fee (Annual fee on Trust's Chainlink holdings)
• $500 million — Fee waiver threshold (Amount of Trust assets on which Sponsor Fee is waived for 1 month)
• $200 — Seed capital investment (Amount purchased by Bitwise Asset Management, Inc. on October 22, 2025)
• 8 Shares — Seed Shares purchased (Number of shares purchased by Seed Capital Investor)
• $25 — Per-Share price (Price for Seed Shares and initial Baskets)
• 10,000 Shares — Basket size (Block size for creation and redemption of Shares)
• 100,000 Shares — Initial Baskets shares (Number of shares expected to be purchased by Bitwise Investment Manager, LLC)
• $2,500,000 — Initial Baskets value (Expected purchase value by Bitwise Investment Manager, LLC)
• November 18, 2025 — Filing date (Date S-1/A was filed with the SEC)
• 4:00 p.m. ET — NAV calculation time (Time at which the Pricing Benchmark is calculated daily)

Key Players & Entities

• Bitwise Chainlink ETF (company) — Registrant and exchange-traded product
• Bitwise Investment Advisers, LLC (company) — Sponsor and manager of the Trust
• Chainlink (dollar_amount) — Primary investment asset of the Trust
• Coinbase Custody Trust Company, LLC (company) — Custodian for the Trust's Chainlink holdings
• NYSE Arca, Inc. (company) — Anticipated listing exchange for CLNK shares
• CME CF Chainlink–Dollar Reference Rate – New York Variant (company) — Pricing Benchmark for the Trust's NAV
• CF Benchmarks Ltd. (company) — Benchmark Provider for the Pricing Benchmark
• Bitwise Asset Management, Inc. (company) — Parent of the Sponsor and Seed Capital Investor
• Bitwise Investment Manager, LLC (company) — Affiliate of the Sponsor, expected to purchase initial Baskets
• U.S. Securities and Exchange Commission (regulator) — Regulatory body overseeing the registration statement

FAQ

Risk Factors

• Chainlink Market Volatility [high — market]: The value of Chainlink (LINK) is subject to extreme volatility, influenced by factors such as market sentiment, regulatory developments, technological advancements, and broader cryptocurrency market trends. The Trust's NAV will fluctuate directly with the price of Chainlink, posing significant risk to investors.
• Regulatory Uncertainty for Digital Assets [high — regulatory]: The regulatory landscape for digital assets, including Chainlink, is evolving and uncertain. Changes in regulations in the U.S. or globally could adversely affect the price of Chainlink, the Trust's ability to operate, or the demand for its shares.
• Custody and Security Risks [medium — operational]: The Trust's Chainlink holdings are held by Coinbase Custody Trust Company, LLC. While robust security measures are expected, there remains a risk of unauthorized access, theft, or loss of the digital assets held in custody, which could result in a loss of Trust assets.
• Management Fee Impact [medium — financial]: The Trust has a unitary management fee of 0.34% per annum. While a waiver is in place for the first month on assets up to $500 million, this ongoing fee will reduce the net returns to investors over time.
• Reliance on CME CF Chainlink–Dollar Reference Rate [medium — market]: The Trust uses the CME CF Chainlink–Dollar Reference Rate – New York Variant for pricing. Any disruption, inaccuracy, or manipulation of this reference rate could lead to an inaccurate NAV calculation and negatively impact investors.
• Staking Risks (Future) [medium — operational]: The Trust intends to amend its registration to include staking as a secondary objective. Staking involves risks such as slashing penalties, validator downtime, and smart contract vulnerabilities, which could lead to a loss of Chainlink assets.
• Limited Recourse for Investors [low — legal]: Investors in the Trust have limited recourse against the Sponsor, the Trustee, or other service providers in the event of losses due to market fluctuations or operational failures, as outlined in the Trust's governing documents.

Industry Context

The cryptocurrency ETF market is rapidly evolving, with increasing institutional interest in digital assets. Chainlink, as a leading oracle network, has seen significant adoption, making it a target for investment products. However, the space is highly competitive, with other digital asset ETFs and direct investment options available, all subject to significant regulatory scrutiny and market volatility.

Regulatory Implications

The filing of an S-1/A indicates the Trust is seeking SEC registration, subject to regulatory approval. The evolving regulatory landscape for digital assets poses a significant risk, as new rules or interpretations could impact Chainlink's value, the Trust's operations, or its ability to remain listed.

What Investors Should Do

1. Review the fee structure carefully, including the 0.34% management fee and the initial waiver terms.
2. Assess personal risk tolerance for highly volatile digital assets like Chainlink.
3. Monitor regulatory developments concerning digital assets and cryptocurrencies.
4. Understand the custody arrangements and the role of Coinbase Custody Trust Company, LLC.

Key Dates

• 2025-10-22: Seed Capital Investment — Bitwise Asset Management, Inc. provided $200 in seed capital, purchasing 8 shares at $25 each, establishing the initial basis for the Trust's audit.
• 2025-11-18: S-1/A Filing Date — The Trust filed its amended registration statement with the SEC, providing detailed information about its structure, operations, fees, and risks.

Glossary

Chainlink

A decentralized oracle network that provides real-world data to smart contracts on the blockchain. (The underlying digital asset that the Bitwise Chainlink ETF aims to provide exposure to.)

S-1/A

An amended registration statement filed with the U.S. Securities and Exchange Commission (SEC) for new securities offerings. (This filing provides the comprehensive details investors need to understand the ETF's structure, fees, risks, and operations.)

Unitary Management Fee

A single, all-inclusive annual fee charged by the sponsor for managing the trust's assets. (The CLNK ETF has a unitary management fee of 0.34%, which impacts the net return for investors.)

CME CF Chainlink–Dollar Reference Rate – New York Variant

A benchmark rate for the price of Chainlink against the US Dollar, calculated by CME Group. (This rate is used by the Trust to determine the Net Asset Value (NAV) of its Chainlink holdings.)

Coinbase Custody Trust Company, LLC

A qualified custodian specializing in the secure storage of digital assets. (Serves as the custodian for the Trust's Chainlink holdings, ensuring their safekeeping.)

Basket

A block of creation units of ETF shares, used by authorized participants to create or redeem ETF shares with the Trust. (The initial creation of shares will be in Baskets, with an expected size of 100,000 shares for $2,500,000.)

NAV (Net Asset Value)

The per-share market value of a fund, calculated by taking the total value of its assets, subtracting liabilities, and dividing by the number of outstanding shares. (The NAV of the CLNK ETF will be directly tied to the price of Chainlink, calculated daily at 4:00 p.m. ET.)

Staking

The process of actively participating in transaction validation (similar to mining) on a Proof-of-Stake (PoS) blockchain to earn rewards. (The Trust intends to incorporate staking as a future investment objective to generate additional Chainlink.)

Year-Over-Year Comparison

This is the initial S-1/A filing for the Bitwise Chainlink ETF (CLNK), so there is no prior filing to compare against. Key metrics such as revenue, net income, and operating margins are not applicable at this pre-launch stage. The filing establishes the initial structure, fees (0.34% management fee), seed capital ($200), and planned initial Baskets ($2,500,000) for the Trust.

Key Financial Figures

• $500 million — ive the entire Sponsor Fee on the first $500 million of Trust assets. When the Trust creat
• $200 — eed Capital Investor agreed to purchase $200 in Shares on October 22, 2025, and on O
• $25 — ery of 8 Shares at a per-Share price of $25 (the “Seed Shares”). The $2
• $1.235 billion — uo; upon the earliest of (i) its having $1.235 billion or more in annual revenues, (ii) at lea
• $700 million — more in annual revenues, (ii) at least $700 million in market value of Shares being held by
• $1.0 billion — affiliates, (iii) its issuing more than $1.0 billion of non-convertible debt over a three-ye

Filing Documents

• ea0265926-s1a1_bitwise.htm (S-1/A) — 1461KB
• ea026592601ex3-3_bitwise.htm (EX-3.3) — 203KB
• ea026592601ex5-1_bitwise.htm (EX-5.1) — 16KB
• ea026592601ex8-1_bitwise.htm (EX-8.1) — 15KB
• ea026592601ex10-1_bitwise.htm (EX-10.1) — 25KB
• ea026592601ex10-2_bitwise.htm (EX-10.2) — 323KB
• ea026592601ex10-3_bitwise.htm (EX-10.3) — 75KB
• ea026592601ex10-4_bitwise.htm (EX-10.4) — 314KB
• ea026592601ex10-5_bitwise.htm (EX-10.5) — 21KB
• ea026592601ex10-6_bitwise.htm (EX-10.6) — 135KB
• ea026592601ex10-7_bitwise.htm (EX-10.7) — 105KB
• ea026592601ex10-8_bitwise.htm (EX-10.8) — 87KB
• ea026592601ex10-9_bitwise.htm (EX-10.9) — 52KB
• ea026592601ex23-1_bitwise.htm (EX-23.1) — 2KB
• ea026592601ex-fee_bitwise.htm (EX-FILING FEES) — 12KB
• image_001.jpg (GRAPHIC) — 6KB
• image_002.jpg (GRAPHIC) — 4KB
• ex5-1_001.jpg (GRAPHIC) — 4KB
• ex10-4_001.jpg (GRAPHIC) — 5KB
• ex10-5_001.jpg (GRAPHIC) — 2KB
• ex10-6_001.jpg (GRAPHIC) — 5KB
• ex10-7_001.jpg (GRAPHIC) — 3KB
• ex10-8_001.jpg (GRAPHIC) — 7KB
• ex8-1_001.jpg (GRAPHIC) — 4KB
• 0001213900-25-112216.txt ( ) — 3013KB
• ea026592601ex-fee_bitwise_htm.xml (XML) — 4KB

Risk Factors

Risk Factors 12 CHAINLINK, CHAINLINK MARKET AND REGULATION OF CHAINLINK 68 THE TRUST AND Chainlink PRICES 74 Calculation of NAV 80 ADDITIONAL INFORMATION ABOUT THE TRUST 82 The Trust’s Service Providers 88 Custody of the Trust’s Assets 91 THE PRIME EXECUTION AGENT AND the TRADE CREDIT LENDER 93 Form of Shares 99 Transfer of Shares 100 SEED CAPITAL INVESTOR 100 Plan of Distribution 101 Creation and Redemption of Shares 103

Use of Proceeds

Use of Proceeds 110 110 Conflicts of Interest 111 FIDUCIARY AND REGULATORY DUTIES AND OBLIGATIONS OF THE SPONSOR 112 Liability and Indemnification 114 Provisions of Law 116 Management; Voting by Shareholders 117 Meetings 117 Books and Records 117 118 Fiscal Year 118 GOVERNING LAW; CONSENT TO DELAWARE JURISDICTION 118 Legal Matters 119 Experts 119 Material Contracts 120 UNITED STATES FEDERAL INCOME TAX CONSEQUENCES 127 Purchases By Employee Benefit Plans 133 Information You Should Know 135 SUMMARY OF PROMOTIONAL AND SALES MATERIAL 135 Intellectual Property 136 Where You Can Find More Information 136 Privacy Policy 137 REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM F-1 F-2 This Prospectus contains information you should consider when making an investment decision about the Shares. You may rely on the information contained in this Prospectus. The Trust and the Sponsor have not authorized any person to provide you with different information and, if anyone provides you with different or inconsistent information, you should not rely on it. This Prospectus is not an offer to sell the Shares in any jurisdiction where the offer or sale of the Shares is not permitted. The Shares are not registered for public sale in any jurisdiction other than the United States. Until _____________, 2025 (25 days after the date of this prospectus), all dealers effecting transactions in the Shares, whether or not participating in this distribution, may be required to deliver a prospectus. This requirement is in addition to the obligations of dealers to deliver a prospectus when acting as underwriters and with respect to unsold allotments or subscriptions. The Sponsor first intends to use this prospectus on _____________, 2025. i REGARDING FORWAR

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