Cathie Wood’s ARK Invest filed S-1 registration statements with the SEC on January 23 for two new exchange-traded funds targeting the CoinDesk 20 Index. In a move diverging from the recent flood of spot asset applications, ARK structured these funds as futures-based products, a mechanism likely chosen to bypass the regulatory gridlock facing multi-asset spot approvals.
The filings introduce the ARK CoinDesk 20 Crypto ETF and a tactical variant, the ARK CoinDesk 20 ex-Bitcoin Crypto ETF. Unlike Franklin Templeton’s competing proposal, which seeks to hold the underlying tokens directly, ARK’s funds will gain exposure through cash-settled futures contracts traded on regulated exchanges.
The ‘Ex-Bitcoin’ Short Strategy
The most notable structural innovation appears in the ex-Bitcoin fund. According to the filing, ARK plans to synthesize “altcoin-only” exposure by holding long positions in CoinDesk 20 Index futures while simultaneously shorting CME Bitcoin futures. This allows investors to isolate the performance of assets like Ethereum and Solana without doubling down on Bitcoin beta.
The weighting implications are significant. In the standard fund, Bitcoin commands a capped 32.4% share, followed closely by Ethereum (20.7%). However, XRP holds a surprisingly heavy 19.9% allocation, placing it well above Solana (13.9%) and Cardano (3.8%).
Regulatory Arbitrage
ARK’s pivot to futures signals a calculation that the SEC is not yet ready to approve spot ETFs for assets classified as “crypto asset securities” in ongoing litigation. While Bitcoin ($89,400) and Ethereum ($2,940) have secured spot status, components of the CoinDesk 20 like Solana and Cardano remain in regulatory limbo. By wrapping these assets in a futures structure, ARK attempts to front-run spot issuers who must wait for clearer legislative guidance.
“To achieve the fund’s objective, the Trust will invest in Index Futures and will hold its remaining assets in cash… The fund won’t provide spot exposure to these crypto assets.”
Both funds are slated for listing on the NYSE Arca, though no ticker symbols were disclosed. The move comes as the broader crypto market consolidates, with traders looking for vehicles that capture rotation into high-beta alts without the friction of self-custody.
