Canary Marinade Solana ETF (SOLC) — 10-K

Filed 2026-03-31 · Period ending 2025-12-31 · 34,332 words · SEC EDGAR

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# Canary Marinade Solana ETF (SOLC) — 10-K

**Filed:** 2026-03-31
**Period ending:** 2025-12-31
**Accession:** 0001999371-26-007348
**Source:** [SEC EDGAR](https://www.sec.gov/Archives/edgar/data/2041869/000199937126007348/)
**Origin leaf:** c5a66a1ecc6e6e77f2d2f9a2d91cff0f830d9ef3e29eee800008cd92b289f45e
**Words:** 34,332



---

**
UNITED
STATES**
SECURITIES
AND EXCHANGE COMMISSION
**Washington,
D.C. 20549**
**FORM
10-K**
**(Mark
One)**
| 
| ANNUAL
REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934 | 
|
**For
the fiscal year ended December 31, 2025**
OR
| 
| TRANSITION
REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934 
FOR THE TRANSITION PERIOD FROM_____TO_____. | 
|
****
Commission
File Number **001-42956**
****
Canary
Marinade Solana ETF
(Exact
name of Registrant as specified in its Charter)
| 
Delaware | 
| 
33-6435097 | |
| 
(State or other jurisdiction
of incorporation or organization) | 
| 
(I.R.S. Employer
Identification No.) | |
| 
| 
| 
| |
| 
c/o Canary Capital Group LLC | 
| 
|
| 
8 Cadillac Drive, Suite 300 | 
| 
|
| 
Brentwood, Tennessee | 
| 
37027 | |
| 
(Address of principal executive offices) | 
| 
(Zip Code) | |
Registrants
telephone number, including area code: **(615) 200-0788**
Securities
registered pursuant to Section 12(b) of the Act:
| 
Title
of each class | 
| 
Trading
Symbol | 
| 
Name
of each exchange
on
which registered | |
| 
Canary
Marinade Solana ETF Shares | 
| 
SOLC | 
| 
The
Nasdaq Stock Market, LLC | |
Securities
registered pursuant to Section 12(g) of the Act: **None**
Indicate
by check mark if the Registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act. YES No 
Indicate by check mark if the Registrant is not required to file reports pursuant to Section 13 or 15(d) of the Act. YES No 
Indicate by check mark whether the Registrant: (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities
Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the Registrant was required to file such reports),
and (2) has been subject to such filing requirements for the past 90 days. Yes NO 
Indicate
by check mark whether the Registrant has submitted electronically every Interactive Data File required to be submitted pursuant to Rule
405 of Regulation S-T (232.405 of this chapter) during the preceding 12 months (or for such shorter period that the Registrant
was required to submit such files). Yes NO 
Indicate
by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, smaller reporting company,
or an emerging growth company. See the definitions of large accelerated filer, accelerated filer, smaller
reporting company, and emerging growth company in Rule 12b-2 of the Exchange Act.
| 
Large accelerated filer | 
| 
Accelerated
filer | 
| |
| 
Non-accelerated filer | 
| 
Smaller
reporting company 
Emerging growth company | 
| |
If
an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying
with any new or revised financial accounting standards provided pursuant to Section 13(a) of the Exchange Act. 
Indicate by check
mark whether the registrant has filed a report on and attestation to its managements assessment of the effectiveness of its internal
control over financial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting
firm that prepared or issued its audit report. 
If
securities are registered pursuant to Section 12(b) of the Act, indicate by check mark whether the financial statements of the registrant
included in the filing reflect the correction of an error to previously issued financial statements. 
Indicate
by check mark whether any of those error corrections are restatements that required a recovery analysis of incentive-based compensation
received by any of the registrants executive officers during the relevant recovery period pursuant to 240.10D-1(b). 
Indicate by check mark whether the Registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act). YES No 
State
the aggregate market value of the voting and non-voting common equity held by non-affiliates computed by reference to the price at which
the common equity was last sold, or the average bid and asked price of such common equity, as of the last business day of the registrants
most recently completed second fiscal quarter: $[]
As
of **March 23, 2026**, the Registrant had **70,000** shares outstanding.
DOCUMENTS
INCORPORATED BY REFERENCE: **None**
CAUTIONARY
STATEMENT REGARDING FORWARD-LOOKING STATEMENTS
****
This
Annual Report on Form 10-K (the Annual Report) contains forward-looking statements with respect to the financial
conditions, results of operations, plans, objectives, future performance and business of Canary Marinade Solana ETF (the Trust).
Statements preceded by, followed by or that include words such as may, might, will, should,
expect, plan, anticipate, believe, estimate, predict,
potential or continue, the negative of these terms and other similar expressions are intended to identify
some of the forward-looking statements. All statements (other than statements of historical fact) included in this Annual Report that
address activities, events or developments that will or may occur in the future, including such matters as changes in market prices and
conditions (for Solana and the shares of the Trust (the Shares)), the Trusts operations, Canary Capital Group LLCs
(the Sponsor) plans and references to the Trusts future success and other similar matters are forward-looking statements.
These statements are only predictions. Actual events or results may differ materially. These statements are based on certain assumptions
and analyses the Sponsor made based on its perception of historical trends, current conditions and expected future developments, as well
as other factors appropriate in the circumstances. Whether or not actual results and developments will conform to the Sponsors
expectations and predictions, however, is subject to a number of risks and uncertainties, including:
| 
| the
special considerations discussed in this Annual Report; | |
| 
| general
economic, market and business conditions; | |
| 
| the
use of technology by us and our vendors, including the custodians of the Trust, in conducting
our business, including disruptions in our computer systems and data centers and our transition
to, and quality of, new technology platforms; | |
| 
| changes
in laws or regulations, including those concerning taxes, made by governmental authorities
or regulatory bodies; | |
| 
| the
costs and effects of any litigation or regulatory investigations; | |
| 
| our
ability to maintain a positive reputation; and | |
| 
| other
world economic and political developments. | |
Consequently,
all the forward-looking statements made in this Annual Report are qualified by these cautionary statements, and there can be no assurance
that the actual results or developments the Sponsor anticipates will be realized or, even if substantially realized, that they will result
in the expected consequences to, or have the expected effects on, the Trusts operations or the value of the Shares. Should one
or more of these risks discussed in the Annual Report or other uncertainties materialize, or should underlying assumptions prove incorrect,
actual outcomes may vary materially from those described in forward-looking statements. Forward-looking statements are made based on
the Sponsors beliefs, estimates and opinions on the date the statements are made and neither the Trust nor the Sponsor is under
a duty or undertakes an obligation to update forward-looking statements if these beliefs, estimates and opinions or other circumstances
should change, other than as required by applicable laws. Moreover, neither the Trust, the Sponsor, nor any other person assumes responsibility
for the accuracy and completeness of any of these forward-looking statements. Investors are therefore cautioned against placing undue
reliance on forward-looking statements.
2
**Table
of Contents**
****
| 
| 
| 
Page | |
| 
PART
I | 
| 
| |
| 
Item
1. | 
Business | 
4 | |
| 
Item 1A. | 
Risk Factors | 
25 | |
| 
Item 1B. | 
Unresolved Staff Comments | 
25 | |
| 
Item 1C. | 
Cybersecurity | 
25 | |
| 
Item 2. | 
Properties | 
27 | |
| 
Item 3. | 
Legal Proceedings | 
27 | |
| 
Item 4. | 
Mine Safety Disclosures | 
27 | |
| 
PART II | 
| 
| |
| 
Item 5. | 
Market for Registrants Common Equity , Related Stockholder Matters and Issuer Purchases of Equity Securities | 
28 | |
| 
Item 6. | 
[ Reserved] | 
28 | |
| 
Item 7. | 
Managements Discussion and Analysis of Financial Condition and Results of Operations | 
28 | |
| 
Item 7A. | 
Quantitative and Qualitative Disclosures About Market Risk | 
29 | |
| 
Item 8. | 
Financial Statements and Supplementary Data | 
30 | |
| 
Item 9. | 
Changes in and Disagreements With Accountants on Accounting and Financial Disclosure | 
45 | |
| 
Item 9A. | 
Controls and Procedures | 
45 | |
| 
Item 9B. | 
Other Information | 
45 | |
| 
Item 9C. | 
Disclosure Regarding Foreign Jurisdictions that Prevent Inspections | 
45 | |
| 
PART III | 
| 
| |
| 
Item 10. | 
Directors, Executive Officers and Corporate Governance | 
46 | |
| 
Item 11. | 
Executive Compensation | 
47 | |
| 
Item 12. | 
Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters | 
47 | |
| 
Item 13. | 
Certain Relationships and Related Transactions, and Director Independence | 
47 | |
| 
Item 14. | 
Principal Accounting Fees and Services | 
48 | |
| 
PART IV | 
| 
| |
| 
Item 15. | 
Exhibits, Financial Statement Schedules | 
49 | |
3
PART
I
****
Item
1. Business.
****
**Summary**
****
Canary
Marinade Solana ETF (the Trust) was organized as a Delaware statutory trust on June 6, 2025. The Trust continuously issues
common shares representing fractional undivided beneficial interest in and ownership of the Trust (Shares). The Shares
of the Trust are listed on The Nasdaq Stock Market, LLC (Nasdaq or the Exchange) under the ticker symbol
SOLC. Canary Capital Group LLC, a Delaware limited liability company, is the sponsor of the Trust (the Sponsor), CSC Delaware
Trust Company is the trustee of the Trust (the Trustee), U.S. Bancorp Fund Services, LLC, doing business as U.S. Bank Global
Fund Services, is the transfer agent of the Trust (in such capacity, the Transfer Agent) and the administrator and accounting
agent of the Trust (in such capacity, the Administrator), Paralel Distributors LLC is the marketing agent of the Trust
(the Marketing Agent), BitGo Trust Company, Inc. (BitGo or the Custodian) is the custodian
of the Trusts SOL (SOL), and U.S. Bank, N.A., an affiliate of the Transfer Agent and Administrator, is the cash
custodian of the Trust (the Cash Custodian). The operations of the Trust are governed by the provisions of an Amended and
Restated Trust Agreement, dated June 6, 2025, among the Trustee, the Sponsor, and the shareholders from time to time thereunder (the
Shareholders), as may be amended from time to time (the Trust Agreement). The Trust is an exchange-traded
product. The Trust sells or redeems its Shares in blocks of 10,000 Shares (a Basket) based on the quantity of SOL attributable
to each Share of the Trust (net of accrued but unpaid expenses and liabilities).
The
Trusts inception of operation was November 17, 2025. The Trust had no operations prior to November 17, 2025, other than matters
relating to its organization and the registration of the Shares under the Securities Act of 1933 (the 1933 Act). Canary
Capital Group Inc., (the Seed Capital Investor), an affiliate of the Sponsor, purchased the initial Basket of Shares for
$250,000, at a per-Share price of $25 for these 10,000 Shares (the Seed Basket). Such proceeds were used by the Trust to
purchase SOL at the listing of Shares on the Exchange. The Seed Capital Investor acted as a statutory underwriter in connection with
the initial purchase of the Seed Basket.
The
Sponsor maintains a website https://canaryetfs.com/SOLC/, through which the Trusts
Annual Report on Form 10-K, Quarterly Reports on Form 10-Q, Current Reports on Form 8-K and amendments to those reports filed or furnished
pursuant to Section 13(a) or 15(d) of the Securities Exchange Act of 1934, as amended (the 1934 Act), can be accessed free
of charge, as soon as reasonably practicable after such material is electronically filed with, or furnished to, the U.S. Securities and
Exchange Commission (the SEC). Additional information regarding the Trust may also be found on the SECs EDGAR database
at www.sec.gov.
Investment
Objectives and Principal Investment Strategies
****
*Investment
Objectives*
**
The
investment objective is to seek to provide exposure to the price of SOL held by the Trust, less the expenses of the Trusts operations
and other liabilities. A secondary investment objective is for the Trust to earn additional SOL through the validation of transactions
in the SOL networks (the Solana Network) proof-of-stake (PoS) process. Under normal circumstances,
the Sponsor seeks to stake all of the Trusts SOL through one or more Staking Providers except for SOL reserved by the Sponsor
in its sole discretion to facilitate foreseeable redemption transactions, pay Trust expenses or otherwise protect the Trust and its assets.
In consideration for any staking activity in which the Trust may engage, the Trust would receive a portion of the staking rewards generated
by the Staking Provider, which may be treated as income to the Trust. In seeking to achieve its investment objectives, the Trust holds
SOL and values its Shares daily as of 4:00 p.m. Eastern time (ET) using the same methodology used to calculate the Pricing
Benchmark. All of the Trusts SOL, including staked SOL, is held by the Custodian.
*Principal
Investment Strategies*
**
In
seeking to achieve its investment objectives, the Trust holds SOL and establishes its net asset value (NAV) on each
business day by reference to the CoinDesk Solana CCIXber 60m New York Rate (Pricing Benchmark). The Pricing Benchmark
is calculated by CoinDesk Indices (the Benchmark Provider) based on a 60-minute time-weighted average price of the
SOL-USD CCIXber Reference Rate (the Underlying Index), which is an aggregation of executed trade flow of major SOL
trading platforms (Constituent Platforms). The Benchmark Provider publishes the Pricing Benchmark.
4
Solana
Network Overview
****
SOL
is a digital asset that is created and transmitted through the operations of a peer-to-peer, decentralized network of computers that
operates on cryptographic protocols (the Solana Network). While certain entities such as Solana Labs, Inc. (Solana
Labs) and the Solana Foundation have outsized influence over the Solana Networks development and governance (which was
particularly true during the networks formative years), no single entity owns or operates the Solana Network, the infrastructure
of which is collectively maintained by a decentralized user base. The Solana Network allows people to exchange tokens of value, called
SOL, which are recorded on a public transaction ledger known as a blockchain. SOL can be used to pay for goods and services, including
computational power on the Solana Network, or it can be converted to fiat currencies, such as the U.S. dollar, at rates determined on
digital asset trading platforms or in individual end-user-to-end-user transactions under a barter system. Furthermore, the Solana Network
was designed to allow users to write and implement smart contractsthat is, general-purpose code that executes on every computer
in the network and can instruct the transmission of information and value based on a sophisticated set of logical conditions. Using smart
contracts, users can create markets, store registries of debts or promises, represent the ownership of property, move funds in accordance
with conditional instructions and create digital assets other than SOL on the Solana Network. Smart contract operations are executed
on the Solana Blockchain in exchange for payment of SOL. Like the Ethereum network, the Solana Network is one of a number of projects
intended to expand blockchain use beyond just a peer-to-peer money system.
The
Solana protocol introduced the Proof-of-History (PoH) timestamping mechanism. PoH automatically orders on-chain transactions
by creating a historical record that proves an event has occurred at a specific moment in time. PoH is intended to provide a transaction
processing speed and capacity advantage over other blockchain networks like Bitcoin and Ethereum, which rely on sequential production
of blocks and can lead to delays caused by validator confirmations. PoH is a new blockchain technology that is not widely used. PoH may
not function as intended. For example, it may require more specialized equipment to participate in the network and fail to attract a
significant number of users, or may be subject to outages or fail to function as intended. In addition, there may be flaws in the cryptography
underlying PoH, including flaws that affect functionality of the Solana Network or make the network vulnerable to attack.
In
addition to the PoH mechanism described above, the Solana Network uses a proof-of-stake consensus mechanism to incentivize SOL holders
to validate transactions. Unlike proof-of-work, in which miners expend computational resources to compete to validate transactions and
are rewarded coins in proportion to the amount of computational resources expended, in proof-of-stake, validators risk or stake
coins to compete to be randomly selected to validate transactions and are rewarded coins in proportion to the amount of coins staked.
While the Solana Network does not currently implement slashing, meaning staked SOL is not subject to automatic penalties for validator
misbehavior, there is no guarantee that slashing or similar punitive mechanisms will not be implemented in the future. Proof-of-stake
is viewed as more energy efficient and scalable than proof-of-work and is sometimes referred to as virtual mining.
The
Solana protocol was first conceived by Anatoly Yakovenko in a 2017 whitepaper. Development of the Solana Network is overseen by the Solana
Foundation, a Swiss non-profit organization, and Solana Labs, a Delaware corporation, which administered the original network launch
and token distribution. Although Solana Labs and the Solana Foundation continue to exert significant influence over the direction of
the development of Solana, the Solana Network, like the Ethereum network, is understood to be decentralized and does not require governmental
authorities or financial institution intermediaries to create, transmit or determine the value of SOL.
In
order to own, transfer or use SOL directly on the Solana Network (as opposed to through an intermediary, such as a custodian), a person
generally must have internet access to connect to the Solana Network. SOL transactions may be made directly between end-users without
the need for a third-party intermediary. To prevent the possibility of double-spending SOL, a user must notify the Solana Network of
the transaction by broadcasting the transaction data to its network peers. The Solana Network provides confirmation against double-spending
by memorializing every transaction in the Solana Blockchain, which is publicly accessible and transparent. This memorialization and verification
against double-spending is accomplished through the Solana Network validation process, which adds blocks of data, including
recent transaction information, to the Solana Blockchain. Unlike other blockchains that rely solely on sequential production of blocks
through proof-of-work or proof-of-stake mechanisms, however, the Solana Network introduces PoH, which creates a historical record that
proves an event has occurred at a specific moment in time.
*Smart
Contracts and Development on the Solana Network*
**
Smart
contracts are programs that run on a blockchain that can execute automatically when certain conditions are met. Smart contracts facilitate
the exchange of anything representative of value, such as money, information, property, or voting rights.
Using
smart contracts, users can send or receive digital assets, create markets, store registries of debts or promises, represent ownership
of property or a company, move funds in accordance with conditional instructions and create new digital assets.
Development
on the Solana Network involves building more complex tools on top of smart contracts, such as decentralized apps (DApps)
and organizations that are autonomous, known as decentralized autonomous organizations (DAOs). For example, a company that
distributes charitable donations on behalf of users could hold donated funds in smart contracts that are paid to charities only if the
charity satisfies certain pre-defined conditions.
5
In
total, as of March 2026, more than 680 DApps are currently built on the Solana Network, including DApps in the collectible non-fungible
token, gaming, music streaming, and decentralized finance categories.
Additionally,
the Solana Network has been used for decentralized finance (DeFi), or open finance platforms, which seek to democratize
access to financial services, such as borrowing, lending, custody, trading, derivatives and insurance, by removing third-party intermediaries.
DeFi can allow users to lend and earn interest on their digital assets, exchange one digital asset for another and create derivative
digital assets such as stablecoins, which are digital assets pegged to a reserve asset such as fiat currency. As of March 2026, approximately
$6.85 billion was being used as collateral on DeFi platforms.
In
addition, the Solana Network and other smart contract platforms have been used for creating non-fungible tokens (NFTs).
Unlike digital assets native to smart contract platforms which are fungible and enable the payment of fees for smart contract execution.
Instead, NFTs allow for digital ownership of assets that convey certain rights to other digital or real-world assets. This new paradigm
allows users to own rights to other assets through NFTs, which enable users to trade them with others on the Solana Network. For example,
an NFT may convey rights to a digital asset that exists in an online game or a DApp, and users can trade their NFT in the DApp or game,
and carry them to other digital experiences, creating an entirely new free-market internet-native economy that can be monetized in the
physical world.
As
of the date of this Annual Report, there are several planned upgrades to the Solana Network in various stages of development and implementations:
| 
| Alpenglow
Consensus Protocol: This upgrade aims to significantly improve Solanas finality (i.e., the time it takes for a transaction
to be considered final and irreversible) as well as make the Solana Network faster and more responsive. This would potentially enable
more complex and latency-sensitive applications. Alpenglow would replace the Solana Networks current Proof of History and Tower
BFT systems with newly designed systems. In September 2025, over 98% of voting stake backed the implementation and deployment is scheduled
for Q1 2026. | 
|
| 
| Increased
Network Performance: This series of upgrades (SIMD-268, SIMD-286, SIMD-296) aim to raise limits on the network to enable more expressive
transactions, enable developers to build more complex decentralized applications that compose multiple protocols together, allow for
more transactions per block, and reduced congestion during peak demand. Deployment is expected in Agave 4.1 in 2026. | 
|
| 
| SIMD-123:
Block Revenue Distribution: When SOL is delegated to a validator, only rewards from inflation in the protocol are currently distributed.
However, validators also earn revenue from transaction fees, priority fees and MEV (maximal extractable value) when they produce blocks.
SIMD-123 enables validators to share this block revenue with their delegators automatically through the protocol. Deployment is expected
in Agave 4.1 in 2026. | 
|
*Overview
of the Solana Networks Operations*
**
In
order to own, transfer or use SOL directly on the Solana Network on a peer-to-peer basis (as opposed to through an intermediary, such
as a custodian or centralized exchange), a person generally must have internet access to connect to the Solana Network. SOL transactions
may be made directly between end-users without the need for a third-party intermediary. To prevent the possibility of double-spending
SOL, a user must notify the Solana Network of the transaction by broadcasting the transaction data to its network peers. The Solana Network
provides confirmation against double-spending by memorializing every peer-to-peer transaction in the Solana blockchain, which is publicly
accessible and transparent. This memorialization and verification against double-spending of peer-to-peer transactions is accomplished
through the Solana Network validation process, which adds blocks of data, including recent transaction information, to
the Solana blockchain. Unlike other blockchains that rely solely on sequential production of blocks through proof-of-work or proof-of-stake
mechanisms, the Solana Network introduces proof-of-history, which creates a historical record that proves an event has occurred at a
specific moment in time.
Market
Participants
****
*Validators*
**
Validators
range from Solana enthusiasts to professional operations that design and build dedicated machines and data centers, including clusters,
which are groups of validators that act cohesively and combine their processing to confirm transactions. When a validator confirms a
transaction, the validator and any associated stakers receive a fee.
Staking
rewards on the Solana network are determined by the protocol and are distributed to validators and their associated stakers based on
the proportion of stake they have delegated to a validator relative to the total active stake in the network. The rewards are funded
by inflationary issuance of new tokens and transaction fees collected on the network. The specific amount each validator and staker
receives depends on their share of the total stake, the validators uptime and performance, and the overall network
conditions.
6
The
historical range of staking rewards on the Solana network has varied due to differing levels of network congestion and protocol parameters.
During periods of low congestion, rewards have generally been higher, as validators are able to process more transactions efficiently
and the network can distribute more rewards. Conversely, during periods of high congestion, rewards may decrease due to reduced transaction
throughput and increased competition among validators. The actual annualized reward rate has fluctuated over time, reflecting changes
in network activity, inflation rates, and protocol adjustments.
Staking
rewards on Solana are distributed at regular intervals, typically once per epoch. An epoch on Solana lasts approximately two to three
days, after which rewards are calculated and distributed to validators and their stakers. This regular reward frequency ensures that
participants receive their share of rewards in a timely manner, reflecting their contribution to network security and transaction validation.
During
the course of ordering transactions and validating blocks, validators may be able to prioritize certain transactions in return for increased
transaction fees, an incentive system known as Maximal Extractable Value or MEV. For example, in blockchain networks that
facilitate DeFi protocols in particular, such as the Ethereum Network, users may attempt to gain an advantage over other users by offering
greater transaction fees. Validators less commonly capture MEV in the Solana Network because, unlike the Ethereum Network, it does not
publicly expose transactions before they are accepted by a validator. However, some efforts are underway to help Solana Validators consistently
capture MEV.
*Investment
and Speculative Sector*
**
This
sector includes the investment and trading activities of both private and professional investors and speculators. Historically, larger
financial services institutions are publicly reported to have limited involvement in investment and trading in digital assets, although
the participation landscape is beginning to change. Currently, there is relatively limited use of digital assets in the retail and commercial
marketplace in comparison to relatively extensive use by speculators, and a significant portion of demand for digital assets is generated
by speculators and investors seeking to profit from the short- or long-term holding of digital assets.
The
Solana Network also supports a growing ecosystem of decentralized applications, including DeFi platforms and non-fungible tokens. Furthermore,
SOL investors have sought to earn staking rewards by validating transactions on the Solana Network. Such applications and activities
require the participants to first acquire SOL as the means of transacting with these applications or rewarding such participants engaged
in staking.
*Retail
Sector*
**
The
retail sector includes users transacting in direct peer-to-peer SOL transactions through the direct sending of SOL over the Solana Network.
The retail sector also includes transactions in which consumers purchase goods and services from commercial or service businesses through
direct transactions or third-party service providers, although the use of SOL as a means of payment is still developing and has not yet
been accepted in the same manner as Bitcoin or Ethereum due to its infancy and because SOL has a different purpose than Bitcoin and Ethereum.
*Service
Sector*
**
This
sector includes companies that provide a variety of services including the buying, selling, payment processing and storing of SOL. As
SOL continues to grow in acceptance, it is anticipated that service providers will expand the currently available range of services and
that additional parties will enter the service sector for SOL.
*Solana
Protocol Development and Modifications*
**
Historically
the Solana Networks development has been overseen by Solana Labs, the Solana Foundation and other core developers.
The
Solana Foundation and core developers are able to access and alter the Solana Network source code and, as a result, they are responsible
for quasi-official releases of updates and other changes to the Solana Networks source code.
For
example, in March 2020, the Solana Network launched the Mainnet Beta version of the Solana Network, one month after launching the testnet,
Tour de SOL. Solana Labs led the development of these reference implementations.
The
release of updates to the Solana Networks source code does not guarantee that the updates will be automatically adopted. Users
and nodes must accept any changes made to the Solana source code by downloading the proposed modification of the Solana Networks
source code. A modification of the Solana Networks source code is only effective with respect to the Solana users that download
it. If a modification is accepted only by a percentage of users and validators, a division in the Solana Network will occur such that
one network will run the pre-modification source code and the other network will run the modified source code. Such a division is known
as a fork. See Risk FactorsRisk Factors Related to Digital Assets A Temporary Or Permanent Fork
or a Clone Of The Solana Blockchain Could Adversely Affect The Value Of The Shares.. Consequently, as a practical
matter, a modification to the source code becomes part of the Solana Network only if accepted by participants collectively having a majority
of the processing power on the Solana Network.
7
Core
development of the Solana source code has increasingly focused on modifications of the Solana Network protocol to increase speed and
scalability and also allow for financial and non-financial next generation uses. The Trusts activities are not directly related
to such projects, though such projects may utilize SOL as tokens for the facilitation of their non-financial uses, thereby potentially
increasing demand for SOL and the utility of the Solana Network as a whole. Conversely, projects that operate and are built within the
Solana Blockchain may increase the data flow on the Solana Network and could either bloat the size of the Solana Blockchain
or slow confirmation times.
*Forms
of Attack Against the Solana Network*
**
All
networked systems are vulnerable to various kinds of attacks. As with any computer network, the Solana Network contains certain flaws.
For example, the Solana Network is currently vulnerable to a 51% attack (though the numerical thresholds vary in proof-of-stake)
where, if a party or group were to gain control of more than the relevant threshold of the staked SOL, a malicious actor would be able
to gain full control of the network and the ability to manipulate the Solana Blockchain. As of March 2026, the three largest staking
platforms, Helius, Figment, and Jupiter, collectively controlled approximately 9.6% of the SOL staked on the Solana Network. These platforms
operate across multiple validator nodes and use delegation strategies that concentrate staking influence. Based on publicly available
data, Helius accounts for approximately 3.45%, Figment for approximately 3.10%, and Jupiter for approximately 3.08% of the total staked
SOL. The concentration of stake among these platforms may increase the risk of centralization and validator collusion, particularly if
governance over delegation strategies is limited or coordinated among a small number of decision-makers.
In
addition, many digital asset networks have been subjected to a number of denial of service attacks, which has led to temporary delays
in block creation and in the transfer of SOL.
For
example, on September 14, 2021, the Solana Network experienced a significant disruption, later attributed to a type of denial of service
attack, and was offline for 17 hours, only returning to full functionality 24 hours later. While persons associated with Solana Labs
and/or the Solana Foundation are understood to have played a key role in bringing the network back online, the broader community also
played a key role, as Solana validators coordinated to upgrade and restart the network. Any similar attacks on the Solana Network that
impact the ability to transfer SOL could have a material adverse effect on the price of SOL and the value of the Shares.
Summary
of a SOL Transaction
****
Prior
to engaging in SOL transactions directly on the Solana Network, a user generally must first install on a computer or mobile device a
Solana Network software program that will allow the user to generate a private and public key pair associated with a SOL address. The
Solana Network software program and the SOL address also enable the user to connect to the Solana Network and transfer SOL to, and receive
SOL from, other users.
Each
Solana Network address, or wallet, is associated with a unique public key and private key pair. To receive
SOL, the SOL recipient must provide its public key to the party initiating the transfer. This activity is analogous to a recipient for
a transaction in U.S. dollars providing a routing address in wire instructions to the payor so that cash may be wired to the recipients
account. The payor approves the transfer to the address provided by the recipient by signing a transaction that consists
of the recipients public key with the private key of the address from where the payor is transferring the SOL. The recipient,
however, does not make public or provide to the sender its related private key.
Neither
the recipient nor the sender reveal their private keys in a transaction, because the private key authorizes transfer of the funds in
that address to other users. Therefore, if a user loses the private key, the user may permanently lose access to the SOL contained in
the associated address. Likewise, SOL is irretrievably lost if the private key associated with them is deleted and no backup has been
made.
When
sending SOL, a users Solana Network software program must validate the transaction with the associated private key. In addition,
since every computation on the Solana Network requires processing power, there is a transaction fee involved with the transfer that is
paid by the payor the resulting digitally validated transaction is sent by the users Solana Network software program to the Solana
Network validators to allow transaction confirmation.
Solana
Network validators record and confirm transactions when they validate and add blocks of information to the Solana Blockchain. When a
validator is selected to validate a block, it creates that block, which includes data relating to (i) the verification of newly submitted
and accepted transactions and (ii) a reference to the prior block in the Solana Blockchain to which the new block is being added. The
validator becomes aware of outstanding, unrecorded transactions through the data packet transmission and distribution discussed above.
Upon
the addition of a block of SOL transactions, the Solana Network software program of both the spending party and the receiving party will
show confirmation of the transaction on the Solana Blockchain and reflect an adjustment to the SOL balance in each partys Solana
Network public key, completing the SOL transaction. Once a transaction is confirmed on the Solana Blockchain, it is irreversible.
Some
SOL transactions are conducted off-blockchain and are therefore not recorded in the Solana Blockchain. These
off-blockchain transactions involve the transfer of control over, or ownership of, a specific digital wallet holding
SOL or the reallocation of ownership of certain SOL in a pooled-ownership digital wallet, such as a digital wallet owned by a
digital asset trading platform. In contrast to on-blockchain transactions, which are publicly recorded on the Solana Blockchain,
information and data regarding off-blockchain transactions are generally not publicly available. Therefore, off-blockchain
transactions are not truly SOL transactions in that they do not involve the transfer of transaction data on the Solana Network and
do not reflect a movement of SOL between addresses recorded in the Solana Blockchain. For these reasons, off-blockchain transactions
are subject to risks as any such transfer of SOL ownership is not protected by the protocol behind the Solana Network or recorded
in, and validated through, the blockchain mechanism.
8
Creation
of New SOL
****
*Initial
Creation of SOL*
**
Unlike
other digital assets such as Bitcoin, which are solely created through a progressive mining process, 500 million SOL were created in
connection with the launch of the Solana Network. The initial 500 million SOL were distributed as follows:
Investors:
189 million SOL, or 37.8% of the supply, was sold in private sales to venture capital and other investors conducted between 2018 to 2021.
Solana
Foundation: 52 million SOL, or 10.4% of the supply, was distributed to the Solana Foundation for operational costs incurred in the
development of the Solana Network.
Solana
Labs, Inc.: 64 million SOL, or 12.8% of the supply, was retained by Solana Labs to be used, at least in part, to compensate the employees
of Solana Labs.
Community:
195 million SOL, or 39.0% of the supply, was distributed to the Solana Foundation to be deployed as bounties, incentive programs, marketing
and grants.
Following
the launch of the Solana Network, SOL supply increases through a progressive minting process**.**
****
*Proof-of-Stake
Process*
**
Unlike
proof-of-work, in which validators expend computational resources to compete to validate transactions and are rewarded coins in proportion
to the amount of computational resources expended, in proof-of-stake, validators risk or stake coins to compete to be randomly
selected to validate transactions and are rewarded coins in proportion to the amount of coins staked. While the Solana Network does not
currently implement slashing, meaning staked SOL is not subject to automatic penalties for validator misbehavior, there is no guarantee
that slashing or similar punitive mechanisms will not be implemented in the future. Proof-of-stake is believed by some to be more energy
efficient and scalable than proof-of-work. Every 12 seconds, approximately, a new block is added to the Solana Blockchain with the latest
transactions processed by the network, and the validator that generated this block is awarded SOL.
*Proof-of-History
Process*
**
The
Solana protocol introduced the proof-of-history, which is a timestamping mechanism that automatically orders on-chain transactions by
creating a historical record that proves an event has occurred at a specific moment in time. Proof-of-history is intended to provide
a transaction processing speed and capacity advantage over other blockchain networks like Bitcoin and Ethereum, which rely on sequential
production of blocks and can lead to delays caused by validator confirmations. Proof-of-history is a new blockchain technology that is
not widely used. Proof-of-history may not function as intended. For example, it may require more specialized equipment to participate
in the network and fail to attract a significant number of users, or may be subject to outages or fail to function as intended. In addition,
there may be flaws in the cryptography underlying proof-of-history, including flaws that affect functionality of the Solana Network or
make the network vulnerable to attack.
*Staking*
**
Under
normal circumstances, the Sponsor seeks to stake all of the Trusts SOL through one or more staking providers (each, a Staking
Provider) except for SOL reserved by the Sponsor in its sole discretion to facilitate foreseeable redemption transactions, pay
Trust expenses or otherwise protect the Trust and its assets. The Staking Provider utilizes the hardware, software and services necessary
to enable the establishment of validator nodes and stake the Trusts SOL on the Solana Network. As a result of any staking activity
in which the Trust may engage, the Trust expects to receive certain staking rewards of SOL, which may be treated for federal income tax
purposes as income to the Trusts Shareholders. The Trust itself does not engage in staking activities, including operation of
a validator node. Instead, the staking program is operated through the Trusts service providers, including the Custodian and Staking
Provider. The Staking Provider exercises no discretion as to the amount the Trusts SOL to be staked or timing of the staking activities
(other than as is incidental in establishing or deactivating validator nodes). The Custodian maintains exclusive possession and control
of the private keys associated with any staked SOL at all times. Staking activity comes with a risk of loss of SOL, including in the
form of slashing penalties. Additionally, as part of the activating and exiting processes of
SOL staking, any staked SOL is inaccessible for a period of time determined by a range of factors, resulting in certain liquidity risks
that the Sponsor manages.
9
Staking
rewards generated by the Trusts staking program are subject to fees shared among the Staking Provider and its network of validators.
The amounts owed or paid to the Staking Provider and its network of validators are collectively referred to as the Staking Fees.
The Staking Fees reduce the amount of SOL rewards that are generated from the Trusts staking program that are received by the
Trust. The remainder of the staking rewards are deployed into the staking program, transferred out or sold in connection with the redemption
of Baskets, or transferred or sold by the Sponsor to pay fees due to the Sponsor or Trust expenses and liabilities not assumed by the
Sponsor. The Sponsor is not entitled to any Staking Fees and does not receive any additional compensation for administering the Trusts
staking program. Except for SOL reserved by the Sponsor in its sole discretion to facilitate foreseeable redemption transactions, pay
Trust expenses or otherwise protect the Trust and its assets, all staking rewards are restaked pursuant to the Trusts staking
program.
*Limits
on SOL Supply*
**
The
rate at which new SOL supply has been minted and put into circulation has varied since network launch. Additionally, the Solana protocol
reduces the SOL supply by eliminating 50% of transaction fees paid to the network. As a result, net changes in SOL supply are expected
to vary in the future.
At
network launch, the SOL circulating supply was 8 million SOL. Between network launch and December 31, 2023, the circulating supply of
SOL increased by roughly 7,770% to approximately 621.6 million SOL.
In
February 2021, the SOL supply inflation rate was changed from 0.1% to a new initial inflation rate of 8%. The 8% initial inflation rate
is scheduled to decline in 15% increments until a long-term inflation rate of 1.5% is reached. As of March 2, 2026, the SOL supply issuance
rate was approximately 3.984% on an annual basis before any offsets for eliminated transaction fees.
SOL
Market and SOL Exchanges
****
SOL
can be transferred in direct peer-to-peer transactions through the direct sending of SOL over the Solana Blockchain from one SOL address
to another. Among end-users, SOL can be used to pay other members of the Solana Network for goods and services under what resembles a
barter system. Consumers can also pay merchants and other commercial businesses for goods or services through direct peer-to-peer transactions
on the Solana Blockchain or through third-party service providers.
In
addition to using SOL to engage in transactions, investors may purchase and sell SOL to speculate as to the value of SOL in the SOL market,
or as a long-term investment to diversify their portfolio. The value of SOL within the market is determined, in part, by the supply of
and demand for SOL in the global SOL market, market expectations for the adoption of SOL as a store of value, the number of merchants
that accept SOL as a form of payment, and the volume of peer-to-peer transactions, among other factors.
SOL
spot markets provide investors with a website that permits investors to open accounts with the spot market and then purchase and sell
SOL. Prices for trades on SOL spot markets are typically reported publicly. An investor opening a trading account must deposit an accepted
government-issued currency into their account with the spot market, or a previously acquired digital asset, before they can purchase
or sell assets on the spot market. The process of establishing an account with a SOL spot market and trading SOL is different from, and
should not be confused with, the process of users sending SOL from one SOL address to another SOL address on the Solana Blockchain. This
latter process is an activity that occurs on the Solana Network, while the former is an activity that occurs entirely on the private
website operated by the spot market. The spot market typically records the investors ownership of SOL in its internal books and
records, rather than on the Solana Blockchain. The spot market ordinarily does not transfer SOL to the investor on the Solana Blockchain
unless the investor makes a request to the spot market to withdraw the SOL in their exchange account to an off-exchange SOL wallet.
Outside
of spot markets, SOL can be traded OTC in transactions that are not publicly reported. The OTC market is largely institutional in nature,
and OTC market participants generally consist of institutional entities, such as firms that offer two-sided liquidity for SOL, investment
managers, proprietary trading firms, high-net-worth individuals that trade SOL on a proprietary basis, entities with sizeable SOL holdings,
and family offices. The OTC market provides a relatively flexible market in terms of quotes, price, quantity, and other factors, although
it tends to involve large blocks of SOL. The OTC market has no formal structure and no open-outcry meeting place. Parties engaging in
OTC transactions agree upon a priceoften via phone or emailand then one of the two parties then initiates the transaction.
For example, a seller of SOL could initiate the transaction by sending the SOL to the buyers SOL address. The buyer would then
wire U.S. dollars to the sellers bank account. OTC trades are sometimes hedged and eventually settled with concomitant trades
on SOL spot markets. In addition to spot and OTC markets, SOL futures contracts are offered by certain digital asset derivatives platforms,
allowing investors to speculate on the future price of SOL or hedge existing exposures. These contracts may be cash-settled or physically
settled and are typically traded on regulated or registered trading venues outside of the Solana Blockchain. SOL futures markets may
influence spot market prices and contribute to overall price discovery, though trading volumes and liquidity vary across platforms.
Financial
firms that are authorized to purchase or redeem Shares with the Trust (known as Authorized Participants)deliver, or
facilitate the delivery of, SOL or cash to the Trusts account with the Custodian in exchange for Shares of the Trust, and the
Trust, through the Custodian, delivers SOL or cash when Authorized Participants redeem Shares of the Trust.
10
Competition
****
Thousands
of digital assets, as tracked by CoinMarketCap.com as of February 2026, have been developed since the inception of Bitcoin, which is
currently the most developed digital asset because of the length of time it has been in existence, the investment in the infrastructure
that supports it, and the network of individuals and entities that are using Bitcoin in transactions. While SOL has enjoyed some success
in its limited history, the aggregate value of outstanding SOL is smaller than that of bitcoin and may be eclipsed by the more rapid
development of other digital assets.
Regulation
of Solana and Government Oversight
****
As
digital assets have grown in both popularity and market size, the U.S. Congress and a number of U.S. federal and state agencies (including
FinCEN, SEC, CFTC, FINRA, the Consumer Financial Protection Bureau, the Department of Justice, the Department of Homeland Security, the
Federal Bureau of Investigation, the IRS, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the
Federal Reserve and state financial institution and securities regulators) have been examining the operations of digital asset networks,
digital asset users and the digital asset exchange markets, with particular focus on the extent to which digital assets can be used to
launder the proceeds of illegal activities or fund criminal or terrorist enterprises and the safety and soundness of exchanges or other
service providers that hold or custody digital assets for users. Many of these state and federal agencies have issued consumer advisories
regarding the risks posed by digital assets to investors.
On
January 21, 2025, the SECs acting Chairman Mark T. Uyeda announced the SEC Crypto Task Force. The task force has an objective
of developing a comprehensive and clear regulatory framework for crypto assets. Following the task force announcement, on January 23,
2025, President Trumps Executive Order, titled Strengthening American Leadership in Digital Financial Technology,
aimed to reorient the federal governments approach to digital assets. The Executive Order emphasized the importance of the digital
asset industry in innovation and economic development, and outlined policies to support the growth and use of digital assets, blockchain
technology and related technologies. President Trumps Executive Order also revoked former President Bidens March 9, 2022
Executive Order, titled, Responsible Development of Digital Assets and the U.S. Department of Treasurys July 7,
2022 Framework for International Engagement of Digital Assets and all policies, directives and guidance issued pursuant
to those items produced by the previous administration.It is currently unknown how the actions or recommendations of the task force and
this Executive Order or future governmental actions may impact the status of SOL or any other digital asset as a security
or how SOL or the Trust would be treated under any new or revised regulatory framework.
In
addition, the previous chair of the SEC has stated that the SEC has authority under existing laws to regulate the digital asset sector,
and the SEC, U.S. state securities regulators and several foreign governments have issued warnings and instituted legal proceedings in
which they argue that certain digital assets may be classified as securities and that both those digital assets and any related initial
coin offerings are subject to securities regulations. The outcomes of these proceedings, as well as ongoing and future regulatory actions
may alter, perhaps to a materially adverse extent, the nature of an investment in the Shares or the ability of the Trust to continue
to operate. Additionally, U.S. state and federal as well as foreign regulators and legislatures have taken action against virtual currency
businesses or enacted restrictive regimes in response to adverse publicity arising from hacks, consumer harm, or criminal activity stemming
from virtual currency activity.
In
May 2025, the staff of the Division of Trading and Markets of the SEC released guidance in the form of frequently asked questions relating
to crypto asset activities. The SEC staffs guidance addressed several key points for broker-dealers acting as Authorized Participants.
According to the guidance, broker-dealers may custody non-security crypto assets and may treat crypto asset securities as being held
at a permissible control location under Exchange Act Rule 15c3-3(c). The guidance also clarified that broker-dealers may
conduct non-security crypto asset businesses, including facilitating transactions in crypto asset securities that settle in crypto rather
than cash. In addition, broker-dealers may hold crypto assets as proprietary positions for net capital purposes, subject to applicable
haircuts and other limitations. Furthermore, the SEC staff indicated that broker-dealers may engage in in-kind creations and redemptions
for spot crypto exchange-traded products. However, this guidance is non-binding, and may be modified, superseded, or withdrawn at any
time without notice, as emphasized in the guidance. Additionally, there is no guarantee that Authorized Participants will actually transact
in-kind at all despite this guidance.
The
SEC has also recently proposed amendments to the custody rules under Rule 206(4)-2 of the Investment Advisers Act. The proposed rule
changes would amend the definition of a qualified custodian under Rule 206(4)-2(d)(6) and expand the current custody rule
under Rule 206(4)-2 to cover digital assets and related advisory activities. If enacted as proposed, these rules would likely impose
additional regulatory requirements with respect to the custody and storage of digital assets and could lead to additional regulatory
oversight of the digital asset ecosystem more broadly.
Various
foreign jurisdictions have, and may continue to, in the near future, adopt laws, regulations or directives that affect a digital asset
network, the Digital Asset Markets, and their users, particularly digital asset trading platforms and service providers that fall within
such jurisdictions regulatory scope. For example:
11
| 
| China
has made transacting in cryptocurrencies illegal for Chinese citizens in mainland China,
and additional restrictions may follow. China has banned initial coin offerings and there
have been reports that Chinese regulators have taken action to shut down a number of China-based
digital asset trading platforms. | |
| 
| South
Korea determined to amend its Financial Information Act in March 2020 to require virtual
asset service providers to register and comply with its Anti-Money Laundering (AML)
and counter-terrorism funding framework. These measures also provide the government with
the authority to close digital asset trading platforms that do not comply with specified
processes. South Korea has also banned initial coin offerings. | |
| 
| The
Reserve Bank of India in April 2018 banned the entities it regulates from providing services
to any individuals or business entities dealing with or settling digital assets. In March
2020, this ban was overturned in the Indian Supreme Court, although the Reserve Bank of India
is currently challenging this ruling. | |
| 
| The
United Kingdoms Financial Conduct Authority published final rules in October 2020
banning the sale of derivatives and exchange-traded notes that reference certain types of
digital assets, contending that they are ill-suited to retail investors citing
extreme volatility, valuation challenges and association with financial crime. A new law,
the Financial Services and Markets Act 2023 (FSMA), received royal assent in
June 2023. The FSMA brings digital asset activities within the scope of existing laws governing
financial institutions, markets and assets. | |
| 
| The
Parliament of the European Union approved the text of the Markets in Crypto-Assets Regulation
(MiCA) in April 2023, establishing a regulatory framework for digital asset
services across the European Union. MiCA is intended to serve as a comprehensive regulation
of digital asset markets and imposes various obligations on digital asset issuers and service
providers. The main aims of MiCA are industry regulation, consumer protection, prevention
of market abuse and upholding the integrity of digital asset markets. MiCA was formally approved
by the European Unions member states in 2023 and came into effect in December 2024. | |
There
remains significant uncertainty regarding foreign governments future actions with respect to the regulation of digital assets
and digital asset trading platforms. Such laws, regulations or directives may conflict with those of the United States and may negatively
impact the acceptance of SOL by users, merchants and service providers outside the United States and may therefore impede the growth
or sustainability of the Solana ecosystem in the United States and globally, or otherwise negatively affect the value of SOL held by
the Trust. The effect of any future regulatory change on the Trust or the SOL held by the Trust is impossible to predict, but such change
could be substantial and adverse to the Trust and the value of the Shares.
**Custody
of the Trusts Assets**
****
*SOL
Custody Generally*
**
The
Trusts Custodians keep custody of the Trusts SOL. The Trusts SOL is held in segregated accounts opened in the name
of the Trust on the Custodians books and records.
Custody
of SOL typically involves the generation, storage and utilization of private keys. These private keys are used to effect transfer transactions
(i.e., transfers of SOL from an address associated with the private key to another address). Cold storage is a safeguarding method with
multiple layers of protections and protocols, by which the private key(s) corresponding to the Trusts SOL is(are) generated and
stored in an offline manner. Private keys are generated in offline computers that are not connected to the Internet so that they are
resistant to hacking. Cold storage of private keys may involve keeping such keys on a non-networked computer or electronic device or
storing the private keys on a storage device or printed medium and deleting the keys from all computers. A limited number of employees
at the Custodians are involved in private key management operations, and the Custodians have represented that no single individual has
access to full private keys. While the Custodians generally keep a substantial portion of the Trusts SOL in cold storage on an
ongoing basis, from time to time, a portion of the Trusts SOL is held in a hot wallet outside of cold storage temporarily as part
of trade facilitation in connection with creations and redemptions of Baskets or to sell SOL to pay Trust expenses.
The
Custodians may receive deposits of SOL but may not send SOL without the use of the corresponding private keys. In order to send SOL when
the private keys are kept in cold storage, unsigned transactions must be physically transferred to the offline cold storage facility
and signed using a software/hardware utility with the corresponding offline keys. At that point, a Custodian can upload the fully signed
transaction to an online network and transfer the SOL. Because the Custodians may need to retrieve private keys from offline storage
prior to initiating transactions, the initiation or crediting of withdrawals or other transactions may be delayed.
The
Sponsor allocates the Trusts SOL between segregated accounts at each Custodian. In determining the amount and percentage of
the Trusts SOL to allocate to each Custodian, the Sponsor considers: (i) the concentration of the Trusts SOL at each
Custodian; (ii) the Sponsors assessment of the safety and security policies and procedures of each Custodian; (iii) the
insurance policies of each Custodian; (iv) the fees and expenses associated with the storage of the Trusts SOL at each
Custodian; (v) the fees and expenses associated with the transfer to or from the account at each Custodian; and (vi) any other
factor the Sponsor deems relevant in making the allocation determination. The Sponsor does not intend to disclose the amount or
percentage of the Trusts SOL held at either Custodian, and the Sponsor may change the allocation between the Custodians at
any time and without notice to Shareholders. The fees and expenses associated with the transfer of SOL between the accounts at each
Custodian will be borne by the Sponsor, not the Trust or the Shareholders. Any transfer of SOL between the accounts at each
Custodian will occur on-chain over the Solana Network. On-chain transactions are subject to all of the risks of the
Solana Network, including the risk that transactions will be made erroneously and are generally irreversible.
12
The
Trust may engage third-party custodians or vendors besides the Custodians and Cash Custodian to provide custody and security services
for all or a portion of its SOL and/or cash, and the Sponsor will pay the custody fees and any other expenses associated with any such
third-party custodian or vendor. The Sponsor is responsible for overseeing the Custodians and the Trusts other service providers.
The Sponsor may, in its sole discretion, add or terminate Custodians at any time. The Sponsor may, in its sole discretion, change the
custodians for the Trusts SOL holdings, but has no obligation whatsoever to do so or to seek any particular terms for the Trust
from other such custodians. However, the Sponsor will only enter into SOL custody arrangements with custodians that meet the Sponsors
criteria, including an agreement to maintain Trust assets in a segregated account, to maintain insurance and to store the Trusts
private keys in cold storage or in such other manner as the Sponsor determines provides reasonable protection for the Trusts assets
from loss or theft. The Trust may hold cash and cash equivalents on a temporary basis to pay expenses or facilitate creation and redemption
transactions. The Trust has entered into a cash custody agreement with the Cash Custodian under which the Cash Custodian acts as custodian
of the Trusts cash.
*Custody
with the Coinbase Custodian*
**
SOL
custodied by the Coinbase Custodian maintained in cold storage is not commingled with assets of Coinbase Custodian or its respective
affiliates or with assets of other customers of the Coinbase Custodian. The Coinbase Custodian has also agreed in the Coinbase Custodial
Services Agreement that it will not, directly or indirectly, lend, pledge, hypothecate or rehypothecate any of the Trusts SOL,
and that the Trusts SOL assets are not treated as general assets of the Coinbase Custodian but are instead considered custodial
assets that remain the Trusts property. Additionally, the Coinbase Custodian has agreed to provide the Trust or its authorized
independent public accountant with confirmation of or access to information sufficient to confirm the SOL held by the Coinbase Custodian
for the Trust and that the Trusts SOL is held in a separate, segregated account under the Trusts name.
The
Coinbase Custodians internal audit team performs periodic internal audits over custody operations, and the Coinbase Custodian
has represented that Systems and Organizational Control (SOC) attestations covering private key management controls are
also performed on the Coinbase Custodian by an external provider.
The
Coinbase Custodians parent, Coinbase Global, Inc. (Coinbase Global) maintains a commercial crime insurance policy
in an amount up to $320 million, which is intended to cover the loss of client assets held by Coinbase Global and all of its subsidiaries,
including the Coinbase Custodian (collectively, Coinbase Global and its subsidiaries are referred to as the Coinbase Insureds),
including from employee collusion or fraud, physical loss including theft, damage of key material, security breach or hack, and fraudulent
transfer. The insurance maintained by the Coinbase Insureds is shared among all of Coinbase Globals customers, is not specific
to the Trust or to customers holding SOL with the Coinbase Custodian and may not be available or sufficient to protect the Trust from
all possible losses or sources of losses.
In
the event of a fork of the SOL blockchain, the Coinbase Custodian may, in its sole discretion, determine whether or not to support (or
cease supporting) either branch of the SOL blockchain entirely, provided that they shall use commercially reasonable efforts to avoid
ceasing to support both branches of such forked protocol and will support, at a minimum, the original digital asset. Provided that the
Coinbase Custodian shall make commercially reasonable efforts to assist the Trust and take the necessary steps to enable the Trust to
retrieve and/or obtain any assets related to a fork, airdrop or similar event, the Coinbase Custodian shall not have any liability, obligation
or responsibility whatsoever arising out of or relating to the operation of an unsupported branch of the SOL blockchain in the event
of a fork. The Coinbase Custodian does not have any responsibility to support airdrops. The Trust Agreement provides, and the Sponsor
has communicated to the Custodians, that the Trust disclaims all rights to Incidental Rights (IR) and IR Virtual Currencies.
Under
the Coinbase Custodial Services Agreement, the Coinbase Custodians liability is subject to the following limitations, among others:
(i) other than with respect to claims and losses arising from fraud or willful misconduct, among others, the Coinbase Custodians
aggregate liability under the Coinbase Custodial Services Agreement shall not exceed the greater of (A) the aggregate fees paid by the
Trust to the Coinbase Custodian in the 12 months prior to the event giving rise to the Coinbase Custodians liability, and (B)
the value of the affected SOL giving rise to the Coinbase Custodians liability; (ii) the Coinbase Custodians aggregate
liability in respect of each cold storage address shall not exceed $100 million; and (iii) in respect of any incidental, indirect, special,
punitive, consequential or similar losses, the Coinbase Custodian is not liable, even if the Coinbase Custodian has been advised of or
knew or should have known of the possibility thereof. The Coinbase Custodian is not liable for delays, suspension of operations, failure
in performance, or interruption of service to the extent it is directly due to a cause or condition beyond the reasonable control of
the Coinbase Custodian.
13
*Custody
with BitGo*
**
BitGo
is also authorized to safeguard the Trusts SOL holdings allocated to it by the Sponsor. BitGo maintains one or more custody accounts
on its books, pursuant to the terms of the BitGo Custodial Services Agreement, for the receipt, safekeeping, and maintenance of SOL.
As
a regulated custodian, BitGo is subject to a detailed statutory and regulatory framework, including holding customer assets in segregated
client accounts on behalf of customers. 100% of Trust assets and private keys safekept by BitGo will be held in cold storage in segregated
accounts and are never commingled with BitGo or other client assets. BitGo applies industry standards, such as CryptoCurrency Security
Standard (CCSS) and SOC1 and SOC2, while also working with the most trusted brands in the industry and offering clients comprehensive
insurance solutions.
The
BitGo ecosystem and architecture for private key management include the BitGo Platform, hardware security modules(HSMs)
and modular services. The BitGo cold custody solution is built on BitGos security to manage keys on behalf of customers. BitGo
only signs transactions that have been authorized by the Sponsor and follow the policies set by the account administrators.
The
primary keys and backup keys are created offline using an Offline Vault Console (OVC) on air gapped laptops during a secure
ceremony to create hardened cryptographic seeds that power the BitGo Platform. This is to ensure only machines which have no access to
the internet are able to securely see private key material.
Undisclosed
personnel at BitGo hold so-called sharded keys. When they are reconstituted, they are able to sign a transaction which moves funds in
the public blockchain. To mitigate collusion, the individuals who have the sharded keys are different from those who have access to the
vaults where the signings happen.
The
private key is reconstituted in the OVC, but only in internal memory. At no point is it displayed or shown to any user. After signing
is done, the key is no longer available in memory. The OVC is run in a read-only disk, so once the laptop is powered off, there is no
non-volatile storage of any kind to write back to disk. The OVC operates using a RAM disk, where it simulates a real hard disk, but it
is completely ephemeral and is wiped as soon as the machine is power cycled or rebooted, thus wiping the reconstituted private key and
preventing it from being copied or compromised.
BitGo
is a South Dakota trust company and the private keys are strategically distributed across various geographic locations within the United
States. In order to enhance security measures, BitGo refrains from disclosing the exact locations of these keys.
At
time of wallet creation, BitGo creates a unique key pair within its HSM in order to give each client a unique wallet on-chain. These
online keys are wrapped by the BitGo HSM and stored within BitGos data vault for the BitGo Platform keys used to sign transactions.
As
all custody wallets are segregated, the existence of SOL held by the Trust can be verified on-chain by the Sponsor or any other authorized
party.
BitGo
cold wallets are supported by a $250 million insurance policy issued by Lloyds of London. The specifics of the policy include
Cyber Insurance, E&O and General specie. Any copying and theft of private keys, insider theft or dishonest acts by BitGo employees
or executives, and loss of keys directly related to BitGos custody of keys would be covered by this amount at a minimum. This
insurance policy is shared among all of BitGos clients and is not specific to the Trust or to customers holding SOL and may not
be available or sufficient to protect the Trust from all possible losses or sources of losses. The Sponsor may purchase additional insurance
coverage through BitGos underwriter, though the Sponsor has not purchased such additional insurance coverage as of the date of
this Annual Report. BitGo is not FDIC-insured. BitGo has established a business continuity plan that will support its ability to conduct
business in the event of a significant business disruption. This plan is reviewed and updated annually, and can be updated more frequently,
if deemed necessary, by BitGo in its sole discretion. Should BitGo be impacted by a significant business disruption, BitGo aims to minimize
business interruption as quickly and efficiently as possible.
BitGos
fork policy is that, in the event of an upcoming modification to the Solana Network that could result in a digital asset network fork
or airdrop, BitGo will use best commercial efforts to provide the value of the forked digital asset. BitGo may not support airdrops,
side chains, or other derivative, enhanced, or forked protocols, tokens, or coins which supplement or interact with an asset supported
by BitGo and assumes absolutely no responsibility in respect to new protocols. The Trust Agreement provides, and the Sponsor has communicated
to the Custodians, that the Trust disclaims all rights to Incidental Rights and IR Virtual Currencies.
The
BitGo Custodial Services Agreement commenced on the effective date, as detailed in the agreement, and will continue for one (1)
year, unless earlier terminated in accordance with the terms of the BitGo Custodial Services Agreement. After the initial term, the
BitGo Custodial Services Agreement will automatically renew for successive renewal terms, as established in the agreement, unless
either party notifies the other of its intention not to renew with prior notice. BitGo may terminate the BitGo Custodial Services
Agreement immediately if BitGo perceives a risk of legal or regulatory non-compliance associated with the Trusts custodial
account activity, among other reasons. The Sponsor may terminate the BitGo Custodial Services Agreement at any time upon providing
at least thirty (30) days written notice to BitGo, paying outstanding amounts and an early termination fee.
14
*Forks
and Airdrops*
**
In
the event of a fork, the Custodial Services Agreements provide that the Custodians may evaluate the consequences of a fork and determine
which chain resulting from the fork it will support as an eligible asset for its customers including the Trust. The Custodians will determine
in their sole discretion whether to support and make available to clients assets resulting from forks or airdrops. In the event that
the Trust may have a right to claim assets resulting from a fork or airdrop, the Custodians will seek approval from the Trust before
claiming such assets on behalf of the Trust and making an entry of ownership on the Custodians books and records for the Trusts
account with the Custodians. The Sponsor will disclaim such assets except as described herein. The Sponsor has not communicated any anticipatory
disclaimer to the Custodians regarding forked or airdropped assets and will disclaim or claim them on a case-by-case basis.
*Custody
of the Trusts Cash*
**
The
Trust generally does not intend to hold cash or cash equivalents except for cash received from financial firms that are authorized to
purchase or redeem Shares with the Trust (known as Authorized Participants) in connection with a creation transaction or
cash held by the Trust pending distribution to Authorized Participants in a redemption transaction or payment of Trust expenses. The
Trust has entered into a Cash Custody Agreement with the Cash Custodian under which the Cash Custodian acts as custodian of the Trusts
cash.
**Key
Generation**
****
Private
keys are generated by the Custodian in key generation ceremonies at secure
locations using offline devices that have never been connected to a network. Private keys are generated
according to detailed procedures using specialized offline devices and within these secure facilities to mitigate risk of hacks, errors,
or other unintended external exposure. Key ceremony processes are highly controlled, require segregation of duties across multiple parties
and are reviewed and witnessed by designated oversight personnel. Thorough validations and signoffs are performed to verify the integrity
and security of key generation ceremonies.
**Key
Storage**
****
The
Custodian holds a majority of SOL in cold storage and is responsible for managing the allocation of SOL between cold and hot storage
for the segregated wallets. Private keys for both hot and cold storage are stored on secure devices. While cold storage requires keys
to be held in an offline manner, hot storage requires private keys to be held online on the Custodians intranet, where they are
more accessible and can be used for more efficient SOL transfers. Some portion of SOL is held in hot storage for the purpose of satisfying
client demands for transfers including in facilitation of redemptions. Within such hot and cold wallets, the Custodian has represented
to the Sponsor that it keeps a substantial majority of assets in cold wallets to promote security, while the balance of assets is kept
in hot wallets to facilitate timely withdrawals. The Custodian has represented to the Sponsor that the percentage of assets maintained
in cold versus hot storage including target percentages may change over time and is determined by ongoing risk analysis and market dynamics,
in which the Custodian balances anticipated liquidity needs for its customers as a class against the anticipated greater security of
cold storage. The Sponsor has no control over the percentage of SOL that the Custodian maintains in cold wallets versus hot wallets.
Each cold storage wallet has a deposit size limitation of $100 million.
The
Custodian has multiple, redundant cold storage sites, which are geographically distributed including sites within the United States.
Cold storage locations of the Custodian are monitored by 24x7 on-site security, video surveillance and alarms, hardened room structures,
and access to these facilities is controlled by multi-person controls, multi-team access rules, and multi-factor authentication. The
locations of the cold storage sites may change at the discretion of the Custodian and are kept confidential by the Custodian for security
purposes. Transactions from cold to hot storage require physical access, according to the above controls, to one or more cold storage
facilities, as well as systematically enforced approvals and integrity verifications, before the secure device can be used to cryptographically
complete the transaction. At no point during this process is the private key removed from the secure device(s) nor the cold storage facility.
Once these security processes have been completed, a transfer on the Solana Network can be executed, as signed using the private keys
held offline in cold storage.
The
Custodian also maintains geographically dispersed backups of private keys, which are cryptographically generated into shards and stored
in separate locations; multiple locations must be accessed to reconstruct a single key. The storage facilities are highly secured, and
include 24x7 on-premises security presence, video surveillance, and alarms for unexpected entry. Access to facilities is controlled by
multi-person controls, multi-team access rules, and multi-factor authentication.
**Security
Procedures**
****
The
Custodian is the custodian of the Trusts private SOL in accordance with the terms and provisions of the Custodial Services
Agreement. Transfers from the SOL Account require certain security procedures, including authorization controls to validate client
requests and private key security procedures for Solana Network transaction signing as described above. Authorization controls may
include usernames, passwords, two-step verification, and telephone call-backs to ensure proper authorization of transaction requests
from the Sponsor or its authorized agents.
15
Transfers
of SOL to the SOL Account are available to the Trust once processed on the Solana Network, subject to successful completion of processes
required by the Custodian.
The
Trust may change the custodial arrangements described in this Annual Report at any time without notice to Shareholders. To the extent
a change in custodial arrangements is deemed material by the Sponsor, the Trust will notify Shareholders in a prospectus supplement and/or
a current report on Form 8-K or in its annual or quarterly reports.
**Forks
and Airdrops**
****
In
the event of a fork, the Custodial Services Agreement provides that the Custodian may evaluate the consequences of a fork and determine
which chain resulting from the fork it will support as an eligible asset for its customers including the Trust. The Custodian will determine
in its sole discretion whether to support and make available to clients assets resulting from forks or airdrops. In the event that the
Trust may have a right to claim assets resulting from a fork or airdrop, the Custodian will seek approval of the Trust before claiming
such assets on behalf of the Trust and making an entry of ownership on the Custodians books and records for the Trusts
account. The Sponsor will disclaim such assets except as described herein. The Sponsor has not communicated any anticipatory disclaimer
to the Custodian regarding forked or airdropped assets and will disclaim or claim them on a case-by-case basis.
**Custody
of the Trusts Cash**
****
The
Trust generally does not intend to hold cash or cash equivalents except for cash received from Authorized Participants in connection
with a creation transaction or cash held by the Trust pending distribution to Authorized Participants in a redemption transaction or
payment of Trust expenses. The Trust has entered into a Cash Custody Agreement with the Cash Custodian under which the Cash Custodian
acts as custodian of the Trusts cash.
**Staked
SOL**
****
Under
normal circumstances, the Sponsor seeks to stake all of the Trusts SOL through one or more Staking Providers, except for SOL reserved
by the Sponsor in its sole discretion to facilitate foreseeable redemption transactions, pay Trust expenses or otherwise protect the
Trust and its assets. Sous Vide Ltd. (Marinade Finance) is expected to be the exclusive Staking Provider through November
2027. The Trust stakes the Trusts SOL on the Solana Network through the Custodian using a software protocol provided by Marinade
Finance that connects the Trust to a pool of verified validator nodes on the Solana Network for automated SOL staking optimization. The
Custodian maintains exclusive possession and control of the private keys associated with any staked SOL at all times. The staking process
includes protocol-defined warm-up, activation and withdrawal periods, during which delegated SOL is temporarily locked and inaccessible.
These phases affect when SOL begins earning rewards, participates in consensus and becomes available for transfer or redelegation.
**Addition
or Termination of a Custodian**
****
If
a Custodian is added or terminated, the Trust will provide Shareholders with notice in a prospectus supplement and/or through a current
report on Form 8-K or in the Trusts annual or quarterly reports.
The
Pricing Benchmark
****
The
net assets of the Trust and its Shares are valued on a daily basis with reference to the Pricing Benchmark as of 4:00 p.m. ET, which
integrates spot market prices from various digital asset trading platforms. The Pricing Benchmark is designed to reflect the performance
of SOL in U.S. dollars. The Trust uses the Pricing Benchmark to calculate its NAV, which is the aggregate U.S. dollar value of SOL in
the Trust, based on the Pricing Benchmark, less its liabilities and expenses. NAV per Share is calculated by dividing NAV
by the number of Shares currently outstanding. NAV and NAV per Share are not measures calculated in accordance with GAAP. NAV is not
intended to be a substitute for the Trusts Principal Market NAV calculated in accordance with GAAP, and NAV per Share is not intended
to be a substitute for the Trusts Principal Market NAV per Share calculated in accordance with GAAP.
The
Sponsor, in its sole discretion, may cause the Trust to price its portfolio based upon an index, benchmark or standard other than
the Pricing Benchmark at any time, with prior notice to the Shareholders, if investment conditions change or the Sponsor believes
that another index, benchmark or standard better aligns with the Trusts investment objectives and strategy. The Sponsor may
make this decision for a number of reasons, including, but not limited to, a determination that the Pricing Benchmark price of SOL
differs materially from the global market price of SOL and/or that third parties are able to purchase and sell SOL on public or
private markets not included among the Constituent Platforms, and such transactions may take place at prices materially higher or
lower than the Pricing Benchmark price. The Sponsor, however, is under no obligation whatsoever to make such changes in any
circumstance. In the event that the Sponsor intends to establish the Trusts NAV by reference to an index, benchmark or
standard other than the Pricing Benchmark, it will provide Shareholders with notice in a prospectus supplement and/or through a
current report on Form 8-K or in the Trusts annual or quarterly reports.
16
*Pricing
Benchmark Methodology*
**
The
Pricing Benchmark is a U.S. dollar-denominated composite reference rate for the price of SOL. The Pricing Benchmark is designed to
(1) mitigate the effects of fraud, manipulation and other anomalous trading activity from impacting the SOL reference rate, (2)
provide a volume-weighted fair value of SOL and (3) appropriately handle and adjust for non-market related events.
The
Benchmark Price is determined by the Benchmark Provider through a process in which trade data is cleansed and compiled in such a manner
as to algorithmically reduce the impact of anomalistic or manipulative trading. This is accomplished by adjusting the weight of each
data input based on price deviation relative to the observable set, as well as recent and long-term trading volume at each venue relative
to the observable set. The Benchmark Price is calculated using non-GAAP methodology and is not used in the Trusts financial statements.
*Determination
of the Benchmark Price*
**
The
Benchmark Price is determined by producing a time-weighted average price (TWAP) of the SOL-USD CCIXber (the Underlying
Index) by using the closing minute values between 3:00 pm and 4:00 pm New York time. The Reference Index applies an algorithm
to the price of SOL on the Constituent Platforms calculated on a per second basis over a 24-hour period.
*The
Underlying Index*
**
The
Underlying Index is designed to represent the fair market price of SOL in U.S. dollars by aggregating real trading data from multiple
cryptocurrency exchanges. The calculation is based on a 24-hour volume-weighted average price, with additional adjustments to ensure
accuracy, reliability, and resistance to manipulation.
To
determine the rate, the Underlying Index collects every individual SOL-USD and SOL-USDC trade from the Constituent Platforms. Each trade
record includes the price at which SOL was traded for USD, the amount (volume) of SOL traded, the exact time the trade occurred, and
the Constituent Platform where the trade took place.
The
system gathers trade data in real time, updating the Underlying Index every time a new SOL-USD and SOL-USDC trade is reported by any
of the Constituent Platform. For each exchange, the system looks at all SOL-USD and SOL-USDC trades that occurred in the past 24 hours.
Each trades price is multiplied by the amount of SOL traded, giving more influence to larger trades. The sum of all these price
x volume values is divided by the total volume traded in the 24-hour period, producing a volume-weighted average price for each
Constituent Platform.
Once
the volume-weighted average prices are calculated for all Constituent Platforms, the Underlying Index combines them, with each Constituent
Platforms contribution to the final rate weighted according to its trading volume. This means that Constituent Platforms with
more trading activity have a greater influence on the final rate. If a Constituent Platform has not reported a recent trade, its influence
on the Underlying Index is reduced over time, ensuring the Underlying Index reflects the most current market conditions. The methodology
also includes an outlier detection step; if a Constituent Platforms price is significantly different from the others, its influence
is reduced or removed to prevent distortion of the index.
*Selection
of Constituent Platforms*
**
To
determine which Constituent Platforms are included in the Underlying Index, a structured and multi-step methodology is followed to ensure
that only the most reliable and representative trading venues are selected. The process begins by establishing a broad universe of potential
platforms, which includes all cryptocurrency exchanges that meet the baseline eligibility criteria set out in the CoinDesk Digital Asset
Policy Methodology. These criteria require that an exchange must be classified as either Category 1 or Category 2, with Category 1 generally
referring to U.S.-licensed exchanges and Category 2 to non-U.S. licensed exchanges that still meet certain standards. There must be at
least two Category 1 exchanges included, ensuring a foundation of regulated and reputable platforms.
From
this initial universe, further quantitative filters are applied. Each exchanges trading volume for the relevant currency pair
over the prior three months is measured as a percentage of the total trading volume across all eligible exchanges. For exchanges already
contributing to the Underlying Index, a minimum of 2% of total volume is required, while new or non-contributing exchanges must meet
a 3% threshold. Additionally, only exchanges that support direct USD-denominated trading for the asset in question are considered. Any
exchange that has been specifically excluded under the policy methodology is automatically ineligible.
Once
the eligible universe is established, exchanges are ranked by their three-month trading volume. The two highest-ranked Category 1
exchanges are selected first. If there are not enough Category 1 exchanges meeting the volume requirement, the threshold is relaxed
until two are included. The remaining Constituent Platforms are then chosen based on overall trading volume, up to a maximum of
eight platforms in total. If, after this process, there are fewer than three eligible exchanges, the volume requirements are further
relaxed to ensure a minimum of three Constituent Platforms are included. In rare cases where even these relaxed standards cannot be
met, the Index Committee will determine the appropriate course of action, which may include further adjustments or, if necessary,
the removal of the index.
17
This
methodology ensures that the Underlying Index is constructed from a universe of exchanges that are not only active and liquid, but also
meet high standards for regulatory compliance and operational integrity. The process is reviewed and updated quarterly, with ongoing
monitoring to address any anomalies or disruptions, thereby maintaining the accuracy and reliability of the index over time.
As
of March 3, 2026, the digital asset trading platforms included in the Underlying Index were Coinbase, Crypto.com, and Kraken. As further
described below, the Sponsor and the Trust reasonably believe each of these digital asset trading platforms are in material compliance
with applicable licensing requirements based on the trading platform category and jurisdiction, as detailed below, and maintain practices
and policies designed to comply with AML and Know-Your-Customer (KYC) regulations.
*Coinbase*:
A U.S.-based trading platform registered as a Money Services Business (MSB) with FinCEN and licensed as a virtual currency
business under the New York Department of Financial Services BitLicense (BitLicense), as well as a money transmitter in
various U.S. states.
*Crypto.com*:
A Singapore-based trading platform that has entities registered as MSBs with FinCEN, and that is licensed as a money transmitter in various
U.S. states and chartered as a non-depository trust company by the New Hampshire Banking Department. Crypto.com does not hold a BitLicense.
*Kraken:*A U.S.-based trading platform that has entities registered as MSBs with FinCEN, and that is licensed as a money transmitter in various
U.S. states and chartered as a Special Purpose Depository Institution by the Wyoming Division of Banking. Kraken does not hold a BitLicense.
Although
the Pricing Benchmark and the Underlying Index are designed to accurately capture the market price of SOL, third parties may be able
to purchase and sell SOL on public or private markets not included among the Constituent Platforms, and such transactions may take place
at prices materially higher or lower than the Benchmark Price. Moreover, there may be variances in the prices of SOL on the various digital
asset trading platforms, including as a result of differences in fee structures or administrative procedures on different digital asset
trading platforms. To the extent such prices differ materially from the Benchmark Price, investors may lose confidence in the Shares
ability to track the market price of SOL.
**Calculation
of NAV**
****
Under
normal circumstances, the Trusts only asset is SOL and, under limited circumstances, cash. The Trusts SOL is carried,
for financial statement purposes, at fair value, as required by U.S. generally accepted accounting principles (GAAP).
The Trusts NAV is determined by the Administrator once each Exchange trading day at 4:00 p.m. ET, or as soon thereafter as
practicable. The NAV for a normal trading day is released after 4:00 p.m. ET. Trading during the core trading session on the
Exchange typically closes at 4:00 p.m. ET. However, NAVs are not officially struck until later in the day (often by 5:30 p.m. and
almost always by 8:00 p.m. ET). The pause between 4:00 p.m. and 5:30 p.m. ET (or later) provides an opportunity for the Sponsor to
algorithmically detect, flag, investigate, and correct unusual pricing should it occur. 
18
The
Administrator calculates the NAV of the Trust by multiplying the number of SOL held by the Trust by the Pricing Benchmark for such day,
adding any additional receivables and subtracting the accrued but unpaid expenses and liabilities of the Trust. The Trusts NAV
per Share is calculated by dividing the Trusts NAV by the number of Shares then outstanding. The Administrator determines the
price of the Trusts SOL by reference to the Pricing Benchmark, which is published between 4:00 p.m. and 4:30 p.m. ET on every
calendar day. The methodology used to calculate the Pricing Benchmark price to value SOL in determining the NAV of the Trust may not
be deemed consistent with GAAP. To the extent the methodology used to calculate the Pricing Benchmark is deemed inconsistent with GAAP,
the Trust will utilize an alternative GAAP-consistent pricing source for purposes of the Trusts periodic financial statements.
The
Sponsor has the exclusive authority to determine the NAV of the Trust. The Sponsor has delegated to the Administrator the responsibility
to calculate the NAV of the Trust and the NAV, based on a pricing source selected by the Sponsor (the Pricing Benchmark). The Administrator
determines the NAV of the Trust each business day. In determining the NAV of the Trust, the Administrator values the SOL held by the
Trust based on the Pricing Benchmark, unless otherwise determined by the Sponsor in its sole discretion. If the Pricing Benchmark is
not available or the Sponsor in its sole discretion determines that the Pricing Benchmark should not be used, the Trusts holdings
may be fair valued in accordance with the policy approved by the Sponsor. The Sponsor does not anticipate that the need to fair
value SOL will be a common occurrence.
The
Indicative Trust Value (the ITV) is calculated by using the prior days closing NAV per Share of the Trust as a base
and updating that value throughout the trading day to reflect changes in the most recently reported price level of the Pricing Benchmark.
The ITV disseminated during the Exchange core trading session hours should not be viewed as an actual real time update of the NAV, because
NAV per Share is calculated only once at the end of each trading day based upon the relevant end of day values of the Trusts investments.
The ITV is disseminated on a per Share basis every 15 seconds during regular Exchange core trading session hours of 9:30 a.m. ET to 4:00
p.m. ET. Solactive disseminates the ITV value through the facilities of CTA/CQ High Speed Lines. In addition, the ITV is available through
on-line information services such as Bloomberg and Reuters.
Dissemination
of the ITV provides additional information that is not otherwise available to the public and may be useful to investors and market professionals
in connection with the trading of the Shares on the Exchange. Investors and market professionals will be able throughout the trading
day to compare the market price of the Trust and the ITV. If the market price of the Shares diverges significantly from the ITV, market
professionals will have an incentive to execute arbitrage trades. For example, if the Trust appears to be trading at a discount compared
to the ITV, a market professional could buy the Shares on the Exchange and sell short futures contracts. Such arbitrage trades can tighten
the tracking between the market price of the Trust and the ITV and thus can be beneficial to all market participants.
The
Sponsor reserves the right to adjust the Share price of the Trust in the future to maintain convenient trading ranges for investors.
Any adjustments would be accomplished through stock splits or reverse stock splits. Such splits would decrease (in the case of a split)
or increase (in the case of a reverse split) the proportionate NAV per Share, but would have no effect on the net assets of the Trust
or the proportionate voting rights of Shareholders or the value of any Shareholders investment.
The
Trusts periodic financial statements may not utilize the NAV of the Trust determined by reference to the Pricing Benchmark to
the extent the methodology used to calculate the Pricing Benchmark is deemed not to be consistent with GAAP. The Trusts periodic
financial statements are prepared in accordance with the Financial Accounting Standards Board (FASB) Accounting Standards
Codification Topic 820, Fair Value Measurements and Disclosures (ASC Topic 820) and utilize an exchange-traded
price from the Trusts principal market for SOL on the Trusts financial statement measurement date. The Sponsor determines
in its sole discretion the valuation sources and policies used to prepare the Trusts financial statements in accordance with GAAP.
The Trust intends to engage a third-party vendor to obtain a price from a principal market for SOL, which will be determined and designated
by such third-party vendor daily based on its consideration of several exchange characteristics, including oversight, and the volume
and frequency of trades. Under GAAP, such a price is expected to be deemed a Level 1 input in accordance with ASC Topic 820 because it
is expected to be a quoted price in active markets for identical assets or liabilities.
To
determine which market is the Trusts principal market (or in the absence of a principal market, the most advantageous market)
for purposes of calculating the Trusts financial statements, the Trust follows ASC 820-10, which outlines the application of
fair value accounting. ASC 820-10 determines fair value to be the price that would be received for SOL in a current sale, which
assumes an orderly transaction between market participants on the measurement date. ASC 820-10 requires the Trust to assume that SOL
is sold in its principal market to market participants or, in the absence of a principal market, the most advantageous market.
Market participants are defined as buyers and sellers in the principal or most advantageous market that are independent,
knowledgeable, and willing and able to transact. The Trust may transact through SOL Trading Counterparties, in multiple markets, and
its application of ASC 820-10 reflects this fact. The Trust anticipates that, while multiple venues and types of markets will be
available to the SOL Trading Counterparties from whom the Sponsor acquires or disposes of the Trusts SOL, the principal
market in each scenario is determined by looking at the market-based level of volume and SOL trading activity. SOL Trading
Counterparties may transact in a Brokered Market, a Dealer Market, Principal-to-Principal Markets and Exchange Markets, each as
defined in the FASB ASC Master Glossary. Based on information reasonably available to the Trust, Exchange Markets have the greatest
volume and level of activity for the asset. The Trust therefore looks to accessible Exchange Markets as opposed to the Brokered
Market, Dealer Market and Principal-to-Principal Markets to determine its principal market. As a result of the aforementioned
analysis, an Exchange Market has been selected as the Trusts principal market. The Trust determines its principal market (or
in the absence of a principal market the most advantageous market) on a quarterly basis to determine which market is its Principal
Market for the purpose of calculating fair value for the creation of quarterly and annual financial statements.
19
The
Sponsor has developed a process for identifying a principal market, as prescribed in ASC 820-10, which outlines the application of fair
value accounting. The process begins by identifying publicly available, well established and reputable SOL trading venues (Exchange Markets,
as defined in the FASB ASC Master Glossary), which are selected by the Sponsor and its affiliates in their sole discretion. Those markets
include Binance, Bitfinex, Bitflyer, Bitstamp, Coinbase Pro, Crypto.com, Gemini, HitBTC, Huobi, Kraken, KuCoin, OKEx, Poloniex. The Sponsor
then, through a service provider, calculates on each valuation period, the highest volume venue during the 60-minute period prior to
4:00 p.m. ET for SOL. The Sponsor then identifies that market as the principal market for SOL during that period, and uses the price
for SOL from that venue at 4:00 p.m. ET as the principal market price.
**The
Trusts Fees and Expenses**
****
The
Trust pays the Sponsor an annual unified fee of 0.50% of the Trusts SOL Holdings (the Sponsor Fee). The Trusts
SOL Holdings is the quantity of the Trusts SOL plus any cash or other assets held by the Trust represented in SOL
as calculated using the Pricing Benchmark price, less its liabilities (which include estimated accrued but unpaid fees and expenses)
represented in SOL as calculated using the Pricing Benchmark price. The Sponsor Fee is paid by the Trust to the Sponsor as compensation
for services performed under the Trust Agreement. The Administrator calculates the Sponsor Fee in respect of each day by reference to
the prior days SOL Holdings. Except for periods during which all or a portion of the Sponsor Fee is being waived, the Sponsor
Fee accrues daily in SOL and is payable monthly in SOL or cash. To the extent there are any on-chain transaction fees incurred in connection
with the transfers of SOL to pay the Sponsor Fee, the Sponsor, and not the Trust, shall bear such fees. The Sponsor may, at its sole
discretion and from time to time, waive all or a portion of the Sponsor Fee for stated periods of time. The Sponsor is under no obligation
to waive any portion of its fees and any such waiver shall create no obligation to waive any such fees during any period not covered
by the waiver.
As
partial consideration for its receipt of the Sponsor Fee, the Sponsor is obligated under the Trust Agreement to assume and pay all fees
and other expenses incurred by the Trust in the ordinary course of its affairs, excluding taxes, but including: (i) the fees of the Trusts
third-party service providers including, but not limited to, the Marketing Agent, the Administrator, the Custodians, the Cash Custodian,
the Transfer Agent, the Benchmark Provider, and the Trustee, (ii) the fees and expenses related to the listing, quotation or trading
of the Shares on the Exchange (including customary legal, marketing and audit fees and expenses), (iii) legal fees and expenses incurred
in the ordinary course, (iv) audit fees, (v) regulatory fees, including, if applicable, any fees relating to the registration of the
Trust and Shares, including any ongoing filings related to the offering of Shares, under the 1933 Act or the 1934 Act, (vi) printing
and mailing costs, (vii) costs of maintaining the Trusts website and (viii) applicable license fees (each, a Sponsor-paid
Expense and collectively, the Sponsor-paid Expenses), provided that any expense that qualifies as an Extraordinary
Expense (as defined below) is not be deemed to be a Sponsor-paid Expense. There is no cap on the amount of Sponsor-paid Expenses. The
Sponsor has also assumed all fees and expenses related to the organization and offering of the Trust and the Shares.
The
Trust may incur certain extraordinary, nonrecurring expenses that are not Sponsor-paid Expenses, including, but not limited to, brokerage
and transaction costs associated with the sale or transfer of SOL, taxes and governmental charges, expenses and costs of any extraordinary
services performed by the Sponsor (or any other service provider) on behalf of the Trust to protect the Trust, the Trusts assets,
or the interests of Shareholders, any indemnification of the Custodian or other agents, service providers or counterparties of the Trust,
and extraordinary legal fees and expenses, including any legal fees and expenses incurred in connection with litigation, regulatory enforcement
or investigation matters (collectively, Extraordinary Expenses). To the extent on-chain transaction fees are incurred in
connection with transfers or sales of SOL to pay Extraordinary Expenses, the Trust bears such fees.
To
the extent it does not have cash readily available, the Sponsor shall cause the transfer or sale of SOL in such quantity as may be
necessary to permit the payment of Trust expenses and liabilities not assumed by the Sponsor or for payment of redemption proceeds
to Authorized Participants. The Trust does not bear any costs associated with the transfer or sale of SOL to pay the Sponsor Fee. To
the extent the Trust incurs any Extraordinary Expenses, the Trust bears the costs of any transfers or sales of SOL to pay such
expenses. The Trust seeks to transfer SOL at such times and in the smallest amounts required to permit such payments as they become
due. With respect to transfers or sales necessary to pay Trust expenses and liabilities that are denominated other than in SOL, the
amount of SOL transferred or sold may vary from time to time depending on the actual sales price of SOL relative to the
Trusts expenses and liabilities (*e.g.*, if the price of SOL falls, the amount of SOL needed to be transferred or sold
to pay an expense denominated in U.S. dollars will increase). To the extent the Trust must buy or sell SOL, the Trust may do so
through a third-party digital asset broker or dealer. When the Trust buys or sells SOL, the Sponsor seeks quotes from its SOL
trading counterparties. Such transactions are typically conducted over the counter rather than over a trading platform or similar
order matching service. The Sponsor selects third party brokers or dealers that it believes have implemented adequate AML, KYC and
other legal compliance policies and procedures.
20
Under
the terms of each Authorized Participant Agreement, the Authorized Participants are responsible for any brokerage or transaction costs
associated with the sale or transfer of SOL incurred in connection with the fulfillment of a creation or redemption order.
Creation
and Redemption of Shares
****
The
Trust creates and redeems Shares from time to time, but only in one or more Baskets. Baskets are only made in exchange for delivery to
the Trust or the distribution by the Trust of the amount of SOL or cash represented by the Baskets being created or redeemed (the Basket
Deposit). The amount of SOL required in a Basket Deposit (the Basket SOL Deposit) and the amount of cash required
in a Basket Deposit (the Basket Cash Deposit) are based on the quantity or value of the quantity, as applicable, of SOL
or cash attributable to each Share of the Trust (net of accrued but unpaid Sponsor Fees and any accrued but unpaid Extraordinary Expenses)
being created or redeemed determined as of 4:00 p.m. ET on the day the order to create or redeem Baskets is properly received.
Authorized
Participants are the only persons that may place orders to create and redeem Baskets. Authorized Participants must be (1) registered
broker-dealers or other securities market participants, such as banks and other financial institutions, that are not required to register
as broker-dealers to engage in securities transactions described below and (2) DTC Participants. To become an Authorized Participant,
a person must enter into an Authorized Participant Agreement with the Marketing Agent.
In
connection with a Cash Creation Order (as defined below) or Cash Redemption Order (as defined below), an Authorized Participant is responsible
for any operational processing and brokerage costs, transfers fees, network fees and stamp taxes (the Transaction Fee).
The Transaction Fee may be reduced, increased or otherwise changed by the Sponsor. Authorized Participants who make deposits with the
Trust in exchange for Baskets receive no fees, commissions or other form of compensation or inducement of any kind from either the Trust
or the Sponsor, and no such person has any obligation or responsibility to the Sponsor or the Trust to effect any sale or resale of Shares.
Certain
Authorized Participants and their agents and affiliates
are expected to be capable of participating directly in the spot markets. Some Authorized Participants or their agents and affiliates
may from time to time buy or sell SOL and may profit in these instances. To the extent that the activities
of Authorized Participants or their agents and affiliates have a meaningful effect on the SOL market,
it could affect the price of SOL and impact the ability of the Authorized Participants to effectively
arbitrage the difference between the price at which the shares trade and the NAV of the Trust. While the Sponsor currently expects that
Authorized Participants and their agents and affiliates direct activities in the SOL
or securities markets in connection with the creation and redemption activities of the Trust does not significantly affect the price
of SOL or the Shares, the impact of the activities of the Trust and its Authorized Participants and
their agents and affiliates on SOL or securities markets is unknown and beyond the control of the
Sponsor.
Each
Authorized Participant is required to be registered as a broker-dealer under the 1934 Act and a member in good standing with FINRA, or
exempt from being or otherwise not required to be licensed as a broker-dealer or a member of FINRA, and is qualified to act as a broker
or dealer in the states or other jurisdictions where the nature of its business so requires. Certain Authorized Participants may also
be regulated under federal and state banking laws and regulations. Each Authorized Participant has its own set of rules and procedures,
internal controls and information barriers as it determines is appropriate in light of its own regulatory regime.
The
following description of the procedures for the creation and redemption of Baskets is only a summary and a Shareholder should refer to
the form of Authorized Participant Agreement for more detail. A form of Authorized Participant Agreement is filed as an exhibit to the
Trusts registration statement.
*Creation
Procedures*
**
On
any business day, an Authorized Participant may place an order with the Transfer Agent to create one or more Baskets. For purposes of
processing creation and redemption orders, a business day means any day other than a day when the Exchange is closed for
regular trading. Purchase orders must be placed by the close of Regular Trading Hours on the Exchange or an earlier time as determined
and communicated by the Sponsor and its Transfer Agent. A purchase order is effective on the date it is received in good order by the
Transfer Agent (Purchase Order Date).
The
manner by which creations are made is dictated by the terms of the Authorized Participant Agreement. Creation orders may be denominated
and settled in an amount of SOL (In-Kind Creation Order) or cash (Cash Creation Order). By placing an In-Kind
Creation Order, an Authorized Participant agrees to facilitate the deposit of SOL with the Custodians, either directly or indirectly
through an Authorized Participant designee. By placing a Cash Creation Order, an Authorized Participant agrees to facilitate the deposit
of cash with the Cash Custodian. An Authorized Participant may not withdraw a creation order without the prior consent of the Sponsor
in its discretion.
Following
an In-Kind Creation Order from an Authorized Participant, the Trusts account at the Custodians must be credited with the
required SOL by 11:00 a.m. ET on the following business day or such other time designated by the Sponsor. The Authorized Participant
or its Authorized Participant designee normally sends the required SOL in an on-chain transaction over the Solana
Network. Such on-chain transactions are subject to the risks associated with Solana Network transactions, including the
irreversibility of transactions made in error or unavoidable delays due to Solana Network congestion. Upon receipt of the Basket SOL
Deposit amount in the Trusts account at the Custodians, the Administrator notifies the Transfer Agent. The Transfer Agent
then directs DTC to credit the number of Shares created to the Authorized Participants DTC account.
21
Following
an Authorized Participants Cash Creation Order, the Trusts account at the Cash Custodian must be credited with the Basket
Cash Deposit amount by 11:00 a.m. ET on the following business day or such other time designated by the Sponsor. Upon receipt of the
Basket Cash Deposit amount in the Trusts account at the Cash Custodian, the Transfer Agent notifies the Marketing Agent, the Authorized
Participant, and the Sponsor that the Basket Cash Amount has been deposited. The Sponsor, on behalf of the Trust, instructs a SOL trading
counterparty to purchase the amount of SOL equivalent in value to the cash deposit amount associated with the creation order, with such
purchase transaction prearranged to be executed, in the Sponsors reasonable efforts, at the Pricing Benchmark price used by the
Trust to calculate NAV, taking into account any spread, commissions, or other trading costs on the applicable Purchase Order Date. The
resulting SOL is deposited in the Trusts account with the Custodians. Any slippage incurred (including, but not limited to, any
trading fees, spreads, or commissions), on a cash equivalent basis, is the responsibility of the Authorized Participant and not of the
Trust or Sponsor. To the extent the execution price of the SOL acquired by the trading counterparty exceeds the cash deposit amount,
such cash difference is the responsibility of the Authorized Participant and not the Trust or Sponsor. The Transfer Agent then directs
DTC to credit the number of Shares created to the Authorized Participants DTC account. To the extent the execution price of the SOL acquired by the trading counterparty is less than the cash deposit amount, such excess cash will be returned to the Authorized Participant.
*Determination
of Required Deposits*
**
The
amount of the Basket Deposit changes from day to day. On each day that the Exchange is open for regular trading, the Administrator adjusts
the quantity of SOL or cash constituting the Basket Deposit as appropriate to reflect the value of the Trusts SOL or cash less
accrued expenses. The computation is made by the Administrator as promptly as practicable after 4:00 p.m. ET or
at an earlier time set forth in the Authorized Participant Agreement or otherwise provided to all Authorized Participants on the date
such order is placed in order for the creation of Baskets to be effected based on the NAV of Shares as next determined on such date after
receipt of the order in proper form.
The
Basket SOL Deposit for a given day is determined by dividing the number of SOL held by the Trust as of the opening of business on that
business day, adjusted for the amount of SOL constituting accrued expenses and other liabilities of the Trust as of the opening of business
on that business day, by the number of Shares outstanding at the opening of business and multiplying such amount by the number of Shares
constituting a Basket. Fractions of SOL smaller than .00000001 are disregarded for purposes of the computation of the Basket SOL Deposit.
The
Basket Cash Deposit is an amount of cash that is in the same proportion to the total assets of the Trust, net of accrued expenses and
other liabilities, on the Purchase Order Date, as the number of Shares constituting a Basket is in proportion to the total number of
Shares outstanding on the Purchase Order Date, plus the amount of any Transaction Fee. For a discussion of how the Trust determines the
value of SOL, see *Calculation of NAV* above. The Basket Cash Deposit so determined is communicated via electronic
mail message to all Authorized Participants.
To
the extent the price at which the Trust executes a SOL purchase in connection with a Cash Creation exceeds the amount described in the
paragraph above, the Authorized Participant that placed such order is responsible for any such difference in price. The Sponsor expects
that its SOL trading counterparties will be able to provide pricing based on the Pricing Benchmark price at 4:00 p.m. ET, which would
minimize or eliminate any such shortfall. However, there can be no guarantee that the price at which the Trust executes SOL trades will
be the Pricing Benchmark price at 4:00 p.m. ET, and Authorized Participants bear the risk of any such differences in price.
*Delivery
of Required Deposits*
**
An
Authorized Participant who places a purchase order must follow the procedures outlined in the Creation Procedures section
of this Annual Report. Upon receipt of the deposit amount by the Custodians or Cash Custodian, as applicable, the Transfer Agent directs
DTC to credit the number of Shares ordered to the Authorized Participants DTC account on the following business day or such later
time as may be agreed upon by the Authorized Participant and the Sponsor, following the Purchase Order Date. The Sponsor has the authority
to set or modify the cut-off time for purchase orders in order for the creation of Baskets to be effected based on the Pricing Benchmark
price at 4:00 p.m. ET as next determined on such date after receipt of the order in proper form. For example, the Sponsor may modify
the cut-off time in the event of an early market close, perceived capacity constraints from the Trusts SOL trading counterparties,
or highly volatile markets. Cut-off times are communicated periodically to Authorized Participants. In circumstances where purchase orders
are due before 4:00 p.m. ET, Authorized Participants will not know the total Basket Deposit at the time they submit a purchase order
for the Basket. The Trusts NAV and the price of a Basket Deposit could rise or fall substantially between the time a purchase
order is submitted and the time the amount of the purchase price in respect thereof is determined, and the risk of such price movements
is borne solely by the Authorized Participant.
22
*Rejection
of Purchase Orders*
**
The
Sponsor or its designee has the absolute right, but does not have any obligation, to reject any purchase order or Basket Deposit for
any reason, including if the Sponsor determines that:
| 
a. | the
purchase order is not in proper form; | |
| 
b. | the
Basket Deposit delivered is not as specified by the Trust through the Sponsor and/or Transfer Agent, and the Sponsor has not consented
to acceptance of an in-kind deposit that varies from the designated portfolio; | 
|
| 
c. | the
acceptance of the Basket Deposit would have certain adverse tax consequences to the Trust; | |
| 
d. | the
acceptance of the Basket Deposit would, in the opinion of counsel, be unlawful; | |
| 
e. | the
acceptance of the Basket Deposit would otherwise, in the discretion of the Trust or the Sponsor, have an adverse effect on the Trust
or the rights of beneficial owners of the Trust; | 
|
| 
f. | the
value of Baskets to be created exceeds a purchase authorization limit afforded to the Authorized Participant by the Trust, and the Authorized
Participant has not deposited an amount in excess of such purchase authorization with the Custodians prior to the designated cut-off
time; or | 
|
| 
g. | there
exist circumstances outside the control of the Trust, the Transfer Agent, or the Sponsor that make it impossible to process purchase
orders for all practical purposes. | 
|
The
Sponsor may in its sole discretion limit the number of Shares created pursuant to purchase orders on any specified day without notice
to the Authorized Participants and may direct the Marketing Agent to reject any purchase orders in excess of such capped amount. The
Sponsor may choose to limit the number of Shares created pursuant to purchase orders when it deems so doing to be in the best interest
of Shareholders. It may choose to do so when it believes the market is too volatile to execute a SOL transaction,
when it believes the price of SOL is being inconsistently, irregularly, or discontinuously published
from SOL trading venues and other data sources, or when it believes other similar circumstances may
create a scenario in which accepting purchase orders would not be in the best interests of the Shareholders. The Sponsor does not believe
that the Trusts ability to arrive at such a determination will have a significant impact on the Shares in the secondary market
because it believes that the ability to create Shares would be reinstated shortly after such determination is made, and any entity desiring
to create Shares would be able to do so once the ability to create Shares is reinstated. However, it is possible that such a determination
would cause the Shares to trade at premiums or discounts relative to the Trusts NAV on the secondary market if arbitrageurs believe
that there is risk that the creation and redemption process is not available, as this process is a component of keeping the price of
the Shares on the secondary market closely aligned to the Trusts NAV.
Neither
the Sponsor, nor the Transfer Agent, nor the Trust are liable for the rejection of any purchase order or Basket Deposit.
*Redemption
Procedures*
**
The
procedures by which an Authorized Participant can redeem one or more Baskets mirror the procedures for the creation of Baskets with an
additional safeguard on SOL being removed from the SOL Account at the Custodians. On any business day, an Authorized Participant may
place an order with the Transfer Agent to redeem one or more Baskets. Redemption orders must be placed by the close of Regular Trading
Hours on the Exchange or an earlier time as determined and communicated by the Sponsor and its agent. A redemption order is effective
on the date it is received by the Transfer Agent (Redemption Order Date).
The
manner by which redemptions are made is dictated by the terms of the Authorized Participant Agreement. Redemption orders are denominated
and settled either in-kind (In-Kind Redemption Order) or in cash (Cash Redemption Order). By placing a redemption
order, an Authorized Participant agrees to facilitate the deposit of Shares with the Transfer Agent. If an Authorized Participant fails
to consummate the foregoing, the order will be cancelled or delayed until the required Shares have been received. An Authorized Participant
may not withdraw a redemption order without the prior consent of the Sponsor in its discretion.
Because
of the time involved in deactivating SOL from the Trusts staking program with the Custodians and the Staking Provider, all Redemption
Orders are generally settled on the second business day following a Redemption Order date. Authorized Participants bear the risk of price
movement of SOL during the period between when the Redemption Order is placed and when the transaction is settled.
In
the case of an In-Kind Redemption Order, the redemption distribution from the Trust consists of a movement of SOL to the Authorized
Participant, or its Authorized Participant designee, representing the amount of SOL held by the Trust, net of accrued expenses and
other liabilities, evidenced by the Shares being redeemed on the Redemption Order Date. In the case of a Cash Redemption Order, the
redemption distribution from the Trust consists of a transfer to the Authorized Participant of an amount of cash that is in the same
proportion to the total assets of the Trust, net of accrued expenses and other liabilities, on the Redemption Order Date, as the
number of Shares to be redeemed under the purchase order is in proportion to the total number of Shares outstanding on the
Redemption Order Date. With respect to either an In-Kind Redemption Order or Cash Redemption Order, the redemption distribution due
from the Trust is delivered once the Transfer Agent notifies the Custodians or Cash Custodian, the Marketing Agent and the Sponsor
that the Authorized Participant has delivered the Shares represented by the Baskets to be redeemed to the Transfer Agents DTC
account. If the Transfer Agents DTC account has not been credited with all of the Shares of the Baskets to be redeemed, the
redemption distribution will be cancelled or delayed until such time as the Transfer Agent confirms receipt of all such
Shares.
23
By
placing a redemption order, an Authorized Participant agrees to deliver the Baskets to be redeemed through DTCs book-entry system
to the Trust by the end of the following business day or such time as may be agreed upon by the Authorized Participant and the Sponsor
following the Redemption Order Date. An Authorized Participant may not withdraw a redemption order without the prior consent of the Sponsor
in its discretion.
*Determination
of Redemption Distribution*
**
The
redemption distribution from the Trust consists of a transfer to the redeeming Authorized Participant or its Authorized Participant designee
of an amount of either SOL (in the case of an In-Kind Redemption Order) or cash (in the case of a Cash Redemption Order) that is determined
in the same manner as the determination of Basket Deposits discussed above.
*Delivery
of Redemption Distribution*
**
The
Transfer Agent notifies the Custodian, the Cash Custodian, the Marketing Agent and the Sponsor that the Shares have been received in
the Transfer Agents DTC account. For an In-Kind Redemption Order, the Sponsor transfers the redemption SOL amount from the Custodian
to the designated wallet address of the Authorized Participant or its Authorized Participant designee. For a Cash Redemption Order, the
redemption distribution due from the Trust is sent by the Cash Custodian to the Authorized Participant on the following business day
or such later time as may be agreed upon by the Authorized Participant and the Sponsor, following the Redemption Order Date if, by 4:00
p.m. ET, on such business day, the Transfer Agents DTC account has been credited with the Baskets to be redeemed. If the Transfer
Agents DTC account has not been credited with all of the Baskets to be redeemed by such time, the redemption distribution will
be cancelled or delayed until such time as the Transfer Agent confirms receipt of all such Shares.
*Rejection
of Redemption Orders*
Redemption
orders must be made in whole Baskets. The Marketing Agent acting by itself or through the person authorized to take redemption orders
in the manner provided in the Authorized Participant Agreement may, in its sole discretion, reject any redemption order (1) the Sponsor
determines not to be in proper form or (2) if requested by the Marketing Agent, the Authorized Participant fails to deliver or execute
supporting documentation evidencing ownership or the Authorized Participants right to deliver sufficient Shares.
*Suspension
of Orders*
**
The
Sponsor may, in its discretion, suspend redemption or creation transactions during any period when the transfer books of the Transfer
Agent are closed or if circumstances outside the control of the Sponsor or its delegate make it for all practicable purposes not feasible
to process Redemption Orders or for any other reason at any time or from time to time. For example, the Sponsor may determine that it
is necessary to suspend redemptions to allow for the orderly liquidation of the Trusts assets. If the Sponsor has difficulty liquidating
the Trusts positions, *e.g.*, because of a market disruption event or an unanticipated delay in the liquidation of a position
in an over-the-counter contract, it may be appropriate to suspend creations and redemptions until such time as such circumstances are
rectified. Neither the Marketing Agent, the person authorized to take redemption orders in the manner provided in the Authorized Participant
Agreement, nor the Custodian are liable to any person or in any way for any loss or damages that may result from any such suspension
or postponement. Any such suspension may cause to price of the Shares to deviate more significantly from the Trusts NAV per Share
than would be the case if such suspension had not occurred. The Trust notifies Shareholders of any such suspension in a prospectus supplement
and/or a current report on Form 8-K or in its annual or quarterly reports.
*Creation
and Redemption Transaction Fees*
**
In
connection with a creation order or redemption order, an Authorized Participant is responsible for the Transaction Fee, which consists
of the operational processing and brokerage costs, transfers fees, network fees and stamp taxes. The Transaction Fee may be reduced,
increased or otherwise changed by the Sponsor.
*Tax
Responsibility*
**
Authorized
Participants are responsible for any transfer tax, sales or use tax, stamp tax, recording tax, value added tax or similar tax or governmental
charge applicable to the creation or redemption of baskets, regardless of whether or not such tax or charge is imposed directly on the
Authorized Participant, and agree to indemnify the Sponsor and the Trust if they are required by law to pay any such tax, together with
any applicable penalties, additions to tax and interest thereon.
*Secondary
Market Transactions*
**
As
noted, the Trust creates and redeems Shares from time to time, but only in one or more Baskets. The creation and redemption of
baskets are only made in exchange for delivery to the Trust or the distribution by the Trust of the amount of SOL or cash equal to
the number of Shares included in the Baskets being created or redeemed determined on the day the order to create or redeem Baskets
is properly received.
24
As
discussed above, Authorized Participants are the only persons that may place orders to create and redeem Baskets. Authorized Participants
must be registered broker-dealers or other securities market participants, such as banks and other financial institutions that are not
required to register as broker-dealers to engage in securities transactions. An Authorized Participant is under no obligation to create
or redeem Baskets, and an Authorized Participant is under no obligation to offer to the public Shares of any Baskets it does create.
Authorized
Participants that do offer to the public Shares from the Baskets they create do so at per-Share offering prices that are expected to
reflect, among other factors, the trading price of the Shares on the Exchange, the NAV of the Trust at the time the Authorized Participant
purchased the Baskets, the NAV of the Shares at the time of the offer of the Shares to the public, the supply of and demand for Shares
at the time of sale, and the liquidity of SOL. Baskets are generally redeemed when the price per Share is at a discount to the NAV per
Share. Shares initially comprising the same basket but offered by Authorized Participants to the public at different times may have different
offering prices. An order for one or more Baskets may be placed by an Authorized Participant on behalf of multiple clients. Authorized
Participants who make deposits with the Trust in exchange for Baskets receive no fees, commissions or other forms of compensation or
inducement of any kind from either the Trust or the Sponsor and no such person has any obligation or responsibility to the Sponsor or
the Trust to effect any sale or resale of Shares.
Shares
are expected to trade in the secondary market on the Exchange. Shares may trade in the secondary market at prices that are lower or higher
relative to their NAV per Share. The amount of the discount or premium in the trading price relative to the NAV per Share may be influenced
by various factors, including the number of Shareholders who seek to purchase or sell Shares in the secondary market and the liquidity
of SOL.
U.S.
Federal Income Tax Consequences
****
The
Sponsor takes the position that the Trust is properly treated as a grantor trust for U.S. federal income tax purposes. Assuming that
the Trust is a grantor trust, the Trust will not be subject to U.S. federal income tax. Rather, if the Trust is a grantor trust,
each beneficial owner of Shares is treated as directly owning its pro rata share of the Trusts assets and a pro rata portion
of the Trusts income, gain, losses and deductions will flow through to each beneficial owner of Shares. If the
Trust were not properly classified as a grantor trust, the Trust might be classified as a partnership for U.S. federal income tax
purposes. However, due to the uncertain treatment of digital assets, with respect to staking and including forks, airdrops and
similar occurrences for U.S. federal income tax purposes, there can be no assurance in this regard. If the Trust were classified as
a partnership for U.S. federal income tax purposes, the tax consequences of owning Shares generally would not be materially
different from the tax consequences described herein, although there might be certain differences, including with respect to timing.
In addition, tax information reports provided to beneficial owners of Shares would be made in a different form. If the Trust were
not classified as either a grantor trust or a partnership for U.S. federal income tax purposes, it would be classified as a
corporation for such purposes. In that event, the Trust would be subject to entity-level U.S. federal income tax (currently at the
rate of 21%) on its net taxable income and certain distributions made by the Trust to shareholders would be treated as taxable
dividends to the extent of the Trusts current and accumulated earnings and profits.
Item
1A. Risk Factors.
****
As
a smaller reporting company, the Trust is not required to provide the information required by this item.
Item
1B. Unresolved Staff Comments.
****
None.
Item
1C. Cybersecurity.
****
*Overview*
**
The
Sponsor has adopted an organizational wide cybersecurity program. The program is administered by the Head of IT of the Sponsor (the Head
of IT). The Sponsors objective, in the development and implementation of this comprehensive cybersecurity program, is to
create effective administrative, technical, and physical safeguards for the protection of personal information of the organization and
its clients.
*Program
Details*
**
The
Sponsor has designated the Head of IT to implement and maintain the cybersecurity program. The Head of IT may delegate any of the Head
of ITs responsibilities to appropriate designees as long as the Head of IT remains primarily responsible for compliance oversight
and administration. The Head of IT is responsible for:
25
| 
1. | Initial
implementation of the cybersecurity program; | |
| 
2. | Ongoing
employee education; | |
| 
3. | Regular
testing of the cybersecurity programs safeguards; | |
| 
4. | Evaluating
the ability of each of our third party service providers to implement and maintain appropriate
security measures for the personal information to which we have permitted them access, and
requiring such third party service providers by contract to implement and maintain appropriate
security measures. | |
| 
5. | Reviewing
the scope of the security measures in the cybersecurity program at least annually, or whenever
there is a material change in our business practices that may implicate the security or integrity
of records containing personal information. | |
*Identification
of Risks and Cybersecurity Governance*
**
To
combat internal risks to the security, confidentiality, and/or integrity of any electronic records containing personal information, and
evaluating and improving, where necessary, the effectiveness of the current safeguards for limiting such risks, the Sponsor has identified
the following risks that are present to its business as well as procedures to help mitigate those risks:
Internal
Threats
| 
1. | There
must be communication to employees on the detailed provisions of the cybersecurity program
at onboarding and annually. | |
| 
2. | Access
to records containing clients personal information shall be limited to those persons
who are reasonably required to know such information. | |
| 
3. | All
security measures shall be reviewed at least annually, or whenever there is a material change
in our business practices that may reasonably implicate the security or integrity of records
containing personal information. | |
| 
4. | Terminated
employees must return all records containing personal information, in any form, that may
at the time of such termination be in the former employees possession. | |
| 
5. | A
terminated employees physical and electronic access to personal information must be
immediately blocked. Such terminated employee shall be required to surrender all keys, IDs
or access codes or badges, business cards, and the like, that permit access to the firms
premises or information. Moreover, such terminated employees remote electronic access
to personal information must be disabled; his/her voicemail access, e-mail access, internet
access, and passwords must be invalidated. | |
| 
6. | Current
employees user IDs and passwords must be managed in accordance with the Sponsors
password policy. | |
| 
7. | Employees
are encouraged to report any suspicious or unauthorized use of customer information. | |
| 
8. | Employees
are prohibited from keeping open files containing personal information on their computer
screen when they are not at their desks. Employees are responsible for locking computer screen
when away from workspace. | |
| 
9. | Employees
must not share login information with co-workers. | |
External
Threats
| 
1. | The
Sponsor maintains reasonably up-to-date firewall protection (if applicable) and operating
system security patches, reasonably designed to maintain the integrity of the personal information,
installed on systems processing personal information. | |
| 
2. | The
Sponsor maintains reasonably up-to-date versions of system security agent software which
must include malware protection and reasonably up-to-date patches and virus definitions,
installed on systems processing personal information. | |
| 
3. | To
the extent technically feasible, personal information stored on portable devices, such as
laptops or tablets, must be password protected, as must all records and files transmitted
across public networks or wirelessly, to the extent technically feasible. | |
| 
4. | All
computer systems must be monitored for unauthorized use of or access to personal information. | |
*Risks
Associated with Remote Client Access and Funds Transfer Requests*
**
Currently,
the Sponsor does not provide its clients with online account access nor does process funds transfer requests. If the firms business
changes to allow for remote client access and funds transfer requests, the Sponsor will update the cybersecurity program accordingly
by identifying the potential risks involved and implementing the appropriate safeguards to protect the clients personal information.
26
*Risks
Associated with Vendors and Other Third Parties*
**
The
Sponsor periodically conducts risk assessments with vendors and other third parties that have access to the Firms networks, customer
data, and other sensitive information.
*Detection
of Unauthorized Activity*
**
Employees
who believe their terminal or computer systems have been subjected to unauthorized activity, or has otherwise been improperly accessed
or used, are required to report the situation to the Head of IT immediately to determine the course of action.
The
Sponsor takes the issue of security seriously. Firm employees who use the technology and information resources of the firm must be aware
that they can be disciplined if they violate this policy. Upon violation of this policy, an employee may be subject to discipline up
to and including discharge. The specific discipline imposed will be determined by a case-by-case basis, taking into consideration the
nature and severity of the violation of the cybersecurity program, prior violations of the policy committed by the individual, state
and federal laws and all other relevant information.
In
a case where the accused person is not a firm employee, the matter shall be submitted to the Head of IT. The Head of IT may refer the
information to law enforcement agencies and/or prosecutors for consideration as to whether criminal charges should be filed against the
alleged violator(s).
*Updates
to the Cybersecurity Program*
**
The
Head of IT reviews the cybersecurity program on a periodic basis and updates the program based on changes in the firms business,
effectiveness of the safeguards, and any additional risk factors that become present. The Head of IT will inform management of the results
of the reviews and any recommendations for improved security arising out of the reviews.
Furthermore,
if an incident occurs that is determined to be in violation of the cybersecurity program, there shall be an immediate mandatory post-incident
review of events and actions taken, if any, with a view to determining whether any changes in our security practices are required to
improve the security of personal information for which the Firm is responsible.
Item
2. Properties.
****
Not
applicable.
Item
3. Legal Proceedings.
****
None.
Item
4. Mine Safety Disclosures.
****
Not
applicable.
27
PART
II
****
Item
5. Market for Registrants Common Equity, Related Stockholder Matters and Issuer Purchases of Equity Securities.
****
The
Shares of the Trust are listed in the accompanying table. The date the Shares of the Trust began trading, their symbols and their primary
listing exchange are indicated below:
| 
Trust | 
Commencement
of Operations | 
Ticker
Symbol | 
Name
of each exchange on which registered | |
| 
Canary
Marinade Solana ETF | 
November
17, 2025 | 
SOLC | 
The
Nasdaq Stock Market, LLC | |
As
of February 25, 2026, there were approximately 25 DTC participating Shareholders of record of the Trust. Because the Trusts Shares
are held by brokers and other institutions on behalf of Shareholders, we are unable to estimate the total number of Shareholders represented
by these record holders.
The
Trust made no distributions to Shareholders during the period ended December 31, 2025. The Trust has no obligation to make periodic distributions
to Shareholders.
**a)**On November 17, 2025, Canary Capital Group Inc., purchased 10,000 Shares at a per-Share price of $25 (Seed Shares)
in a transaction exempt from registration under Section 4(a)(2) of the 1933 Act. Total proceeds to the Trust from the sale of the Seed
Shares was $250,000. The Trusts Shares began trading on the Exchange on November 18, 2025 and since that date, through December
31, 2025 (excluding any redemptions), the Trust sold 80,000 Shares for aggregate proceeds of $2,085,701, including the Seed Shares.
| 
b) | Not
applicable. | |
| 
c) | There
were no redemptions during the period from inception on November 17, 2025, through December
31, 2025. | |
Item
6. [Reserved]
**Item
7. Managements Discussion and Analysis of Financial Condition and Results of Operations.**
****
*The
following discussion and analysis of the Trusts financial condition and results of operations should be read together with, and
is qualified in its entirety by reference to, the Trusts audited financial statements and related notes included elsewhere in
this Annual Report, which have been prepared in accordance with GAAP. See Cautionary Statement Regarding Forward-Looking Statements
above.*
**
*Overview
of the Trust*
**
The
Trust is an exchange-traded fund that issues Shares that are listed and trade on the Exchange. The Trusts investment objective
is to seek to provide exposure to the price of SOL held by the Trust, less the expenses of the Trusts operations and other liabilities.
A secondary investment objective is for the Trust to earn additional SOL through the validation of transactions in the SOL networks
(the Solana Network) proof-of-stake (PoS) process. In seeking to achieve its investment objectives, the Trust
holds SOL and establish its NAV on each business day by reference to the Pricing Benchmark. The Pricing Benchmark is calculated by the
Benchmark Provider based on a 60-minute time-weighted average price of the Underlying Index, which is an aggregation of executed trade
flow of Constituent Platforms. The Benchmark Provider publishes the Pricing Benchmark. The Trust is sponsored by the Sponsor.
The
Shareholders of the Trust take no part in the management or control, and have no voice in, the Trusts operations or business.
Except to elect a successor Sponsor upon the resignation of the Sponsor or as otherwise required by laws of the state of Delaware, Shareholders
have no voting rights under the Trust Agreement.
*Liquidity
and Capital Resources*
**
The
Trust typically does not hold a cash balance except in connection with the creation and redemption of Baskets (*i.e.*,
blocks of 10,000 Shares) or to pay expenses not assumed by the Sponsor. The Trust pays the Sponsor an annual unified fee of 0.50% of
the Trusts SOL Holdings (the Sponsor Fee). The Trusts SOL Holdings is the quantity of the Trusts
SOL plus any cash or other assets held by the Trust represented in SOL as calculated using the Pricing Benchmark price, less its liabilities
(which include estimated accrued but unpaid fees and expenses) represented in SOL as calculated using the Pricing Benchmark price.
The
Trust may also incur certain extraordinary, nonrecurring expenses that are not assumed by the Sponsor, including, but not limited to,
brokerage and transaction costs associated with the sale or transfer of SOL, taxes and governmental charges, expenses and costs of any
extraordinary services performed by the Sponsor (or any other service provider) on behalf of the Trust to protect the Trust, the Trusts
assets, or the interests of Shareholders, any indemnification of the Custodians or other agents, service providers or counterparties
of the Trust, and extraordinary legal fees and expenses, including any legal fees and expenses incurred in connection with litigation,
regulatory enforcement or investigation matters (collectively, Extraordinary Expenses). To the extent on-chain transaction
fees are incurred in connection with transfers or sales of SOL to pay Extraordinary Expenses, the Trust bears such fees.
28
To
the extent it does not have cash readily available, the Sponsor shall cause the transfer or sale of SOL in such quantity as may be
necessary to permit the payment of Trust expenses and liabilities not assumed by the Sponsor or for payment of redemption proceeds
to Authorized Participants. The Trust does not bear any costs associated with the transfer or sale of SOL to pay the Sponsor Fee. To
the extent the Trust incurs any Extraordinary Expenses, the Trust bears the costs of any transfers or sales of SOL to pay such
expenses. The Trust seeks to transfer SOL at such times and in the smallest amounts required to permit such payments as they become
due. With respect to transfers or sales necessary to pay Trust expenses and liabilities that are denominated other than in SOL, the
amount of SOL transferred or sold may vary from time to time depending on the actual sales price of SOL relative to the
Trusts expenses and liabilities (*e.g.*, if the price of SOL falls, the amount of SOL needed to be transferred or sold
to pay an expense denominated in U.S. dollars will increase). To the extent the Trust must buy or sell SOL, the Trust may do so
through a third-party digital asset broker or dealer. When the Trust buys or sells SOL, the Sponsor seeks quotes from its SOL
trading counterparties. Such transactions are typically conducted over the counter rather than over a trading platform or similar
order matching service. The Sponsor selects third party brokers or dealers that it believes have implemented adequate AML, KYC and
other legal compliance policies and procedures.
**Results
of Operations for the Period Ended December 31, 2025**
****
The
Trust commenced operations and its net asset value increased from $0 at the start of business on November 17, 2025, to $1,926,808 on
December 31, 2025. The change in the Trusts net assets resulted from an increase in outstanding Shares, which grew from 0 at the
start of business on November 17, 2025, to 80,000 at December 31, 2025, as a result of 80,000 Shares (80 Baskets) being created and 0
Shares (0 Baskets) being redeemed during the period, and a decrease in the value of SOL, which depreciated 4.57% from $129.81
at November 17, 2025 (the initial share purchase date) to $123.87 at December 31, 2025.
The
net asset value per Share decreased -3.69% from $25.00 as of November 17, 2025 (the initial share purchase date) to $24.09 as of December
31, 2025.
The
net asset value per Share of $27.60 as of November 26, 2025 was the highest during the period, compared with a low of $22.10 as of
December 18, 2025.
The
decrease in net assets from operations for the period ended December 31, 2025 was $(158,893), resulting from staking income of $10,331
and unrealized depreciation of the Trusts SOL investment of $(169,224).
*Off-Balance
Sheet Arrangements*
**
As
of December 31, 2025, the Trust has not used, nor does it expect to use in the future, special purpose entities to facilitate off balance
sheet financing arrangements and has no loan guarantee arrangements or off-balance sheet arrangements of any kind other than agreements
entered into in the normal course of business, which may include indemnification provisions related to certain risks service providers
undertake in performing services which are in the best interests of the Trust. While the Trusts exposure under such indemnification
provisions cannot be estimated, these general business indemnifications are not expected to have a material impact on the Trusts
financial position.
**Critical
Accounting Policies**
****
*Principal
Market and Fair Value Determination*
**
The
Trusts periodic financial statements are prepared in accordance with the FASB ASC Topic 820 and utilize an exchange-traded price
from the Trusts principal market for SOL on the Trusts financial statement measurement date. The Sponsor determined in
its sole discretion the valuation sources and policies used to prepare the Trusts financial statements in accordance with GAAP.
The Trust engaged a third-party vendor to obtain a price from a principal market for SOL, which was determined and designated by such
third-party vendor daily based on its consideration of several exchange characteristics, including oversight, and the volume and frequency
of trades. Under GAAP, such a price is deemed a Level 1 input in accordance with ASC Topic 820 because it is a quoted price in active
markets for identical assets or liabilities.
Item
7A. Quantitative and Qualitative Disclosures About Market Risk.
****
As
a smaller reporting company, the Trust is not required to provide the information required by this item.
29
Item
8. Financial Statements and Supplementary Data.
CANARY MARINADE SOLANA
ETF
INDEX TO FINANCIAL STATEMENTS
| 
| 
Page | |
| 
| 
| |
| 
Report of Independent Registered Public Accounting Firm (PCAOB ID 925) | 
31 | |
| 
Statement of Assets and Liabilities | 
32 | |
| 
Schedule of Investment | 
33 | |
| 
Statement of Operations | 
34 | |
| 
Statement of Changes in Net Assets | 
35 | |
| 
Notes to Financial Statements | 
36 | |
30
**REPORT
OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**
****
To the Sponsor and Shareholders of
Canary Marinade Solana ETF
Opinion on the Financial Statements
We have audited the accompanying statement of assets
and liabilities, including the schedule of investment, of Canary Marinade Solana ETF (the Trust) as of December 31, 2025,
the related statements of operations and changes in net assets for the period from November 17, 2025 (initial share purchase date) through
December 31, 2025, and the related notes (collectively referred to as the financial statements). In our opinion, the financial
statements present fairly, in all material respects, the financial position of the Trust as of December 31, 2025, and the results of its
operations and changes in net assets for the period November 17, 2025 (initial share purchase date) through December 31, 2025, in conformity
with accounting principles generally accepted in the United States of America.
Basis for Opinion
These financial statements are the responsibility
of the Trusts management. Our responsibility is to express an opinion on the Trusts financial statements based on our audit.
We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and
are required to be independent with respect to the Trust in accordance with the U.S. federal securities laws and the applicable rules
and regulations of the Securities and Exchange Commission and the PCAOB.
We conducted our audit in accordance with the standards
of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements
are free of material misstatement whether due to error or fraud. The Trust is not required to have, nor were we engaged to perform, an
audit of its internal control over financial reporting. As part of our audit, we are required to obtain an understanding of internal control
over financial reporting, but not for the purpose of expressing an opinion on the effectiveness of the Trusts internal control
over financial reporting. Accordingly, we express no such opinion.
Our audit included performing procedures to assess
the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond
to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements.
Our procedures included confirmation of digital assets owned as of December 31, 2025, by correspondence with the custodians. Our audit
also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall
presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion.
We have served as Trusts auditors since 2025.
/s/ Cohen
& Company, Ltd.
COHEN & COMPANY, LTD.
Milwaukee, Wisconsin
March 30, 2026
31
| 
Canary Marinade
Solana ETF | |
| 
Statement
of Assets and Liabilities | |
****
****
| 
| | 
December 31, 2025 | | |
| 
ASSETS | | 
| | |
| 
Investments in Solana, at value (Note 2) | | 
$ | 1,926,808 | | |
| 
Total Assets | | 
$ | 1,926,808 | | |
| 
| | 
| | | |
| 
LIABILITIES | | 
| | | |
| 
Payables | | 
| | | |
| 
Payable to Sponsor (Note 3) | | 
$ | | | |
| 
Total Liabilities | | 
| | | |
| 
NET ASSETS | | 
$ | 1,926,808 | | |
| 
| | 
| | | |
| 
NET ASSETS CONSIST OF: | | 
| | | |
| 
Paid-in capital | | 
$ | 2,085,701 | | |
| 
Total distributable earnings (accumulated deficit) | | 
| (158,893 | ) | |
| 
Net Assets | | 
$ | 1,926,808 | | |
| 
| | 
| | | |
| 
Net Asset Value (unlimited shares authorized): | | 
| | | |
| 
Unlimited shares authorized: | | 
| | | |
| 
Net Assets | | 
$ | 1,926,808 | | |
| 
Shares Outstanding^ | | 
| 80,000 | | |
| 
Net Asset Value, Offering and Redemption Price per Share | | 
$ | 24.09 | | |
| 
| | 
| | | |
| 
Investments in securities, at cost | | 
$ | 2,096,032 | | |
| 
^ | 
No Par Value. | | 
| | | |
See
accompanying notes to financial statements.
32
**Canary
Marinade Solana ETF 
Schedule of Investment 
December 31, 2025**
| 
Investments - 100.0% | | 
Quantity | | | 
Fair Value | | |
| 
Crypto Currency - 100.0% | | 
| | | | 
| | | |
| 
Solana | | 
| 15,506 | | | 
$ | 1,926,808 | | |
| 
TOTAL CRYPTO CURRENCY (Cost $2,096,032) | | 
| 15,506 | | | 
| 1,926,808 | | |
| 
| | 
| | | | 
| | | |
| 
TOTAL INVESTMENTS - 100.0% (Cost $2,096,032) | | 
| | | | 
| 1,926,808 | | |
| 
Assets in Excess of Liabilities - 0.0%(a) | | 
| | | | 
| | | |
| 
TOTAL NET ASSETS - 100.0% | | 
| | | | 
$ | 1,926,808 | | |
Percentages
are stated as a percent of net assets.
| 
(a) | Represents less
than 0.5% of total Net Assets. | 
|
See
accompanying notes to financial statements.
33
| 
Canary
Marinade Solana ETF | |
| 
Statement
of Operations | |
| 
| | 
For the Period ended 
December 31, 2025(a) | | |
| 
INVESTMENT INCOME | | 
| | | |
| 
Income: | | 
| | | |
| 
Staking income | | 
$ | 10,331 | | |
| 
Total Income | | 
| 10,331 | | |
| 
| | 
| | | |
| 
Expenses: | | 
| | | |
| 
Sponsor fees (Note 3) | | 
| 969 | | |
| 
Total Expenses | | 
| 969 | | |
| 
Sponsor fees waived (Note 3) | | 
| (969 | ) | |
| 
Net Expenses | | 
| | | |
| 
Net Investment income (loss) | | 
$ | 10,331 | | |
| 
| | 
| | | |
| 
REALIZED AND UNREALIZED GAIN (LOSS) ON INVESTMENTS | | 
| | | |
| 
Net realized gain (loss) on: | | 
| | | |
| 
Investments in securities | | 
$ | | | |
| 
Net change in unrealized appreciation (depreciation) of: | | 
| | | |
| 
Investments in securities | | 
| (169,224 | ) | |
| 
| | 
| | | |
| 
Net realized and unrealized gain (loss) on investments | | 
| (169,224 | ) | |
| 
| | 
| | | |
| 
NET INCREASE (DECREASE) IN NET ASSETS RESULTING FROM OPERATIONS | | 
$ | (158,893 | ) | |
| 
(a) | Initial share purchase date
of fund was 11/17/2025. | 
|
See
accompanying notes to financial statements.
34
| 
Canary
Marinade Solana ETF | |
| 
Statement
of Changes in Net Assets | |
| 
| | 
For the Period ended December 31, 2025(a) | | |
| 
INCREASE (DECREASE) IN NET ASSETS: | | 
| | | |
| 
OPERATIONS | | 
| | | |
| 
Net investment income (loss) | | 
$ | 10,331 | | |
| 
Net realized gain (loss) on investments | | 
| | | |
| 
Net change in unrealized appreciation (depreciation) of investments | | 
| (169,224 | ) | |
| 
Net increase (decrease) in net assets resulting from operations | | 
| (158,893 | ) | |
| 
| | 
| | | |
| 
CAPITAL SHARE TRANSACTIONS | | 
| | | |
| 
Shares sold | | 
| 2,085,701 | | |
| 
Shares redeemed | | 
| | | |
| 
Net increase (decrease) in net assets from capital share transactions | | 
| 2,085,701 | | |
| 
Total increase (decrease) in net assets | | 
| 1,926,808 | | |
| 
| | 
| | | |
| 
NET ASSETS | | 
| | | |
| 
Beginning of Period | | 
| | | |
| 
End of Period | | 
$ | 1,926,808 | | |
| 
(a) | Initial share purchase date
of fund was 11/17/2025. | 
|
See
accompanying notes to financial statements.
35
**Canary
Marinade Solana ETF**
**NOTES
TO THE FINANCIAL STATEMENTS**
**December
31, 2025**
****
| 
1. | Organization | |
****
The
Canary Marinade Solana ETF (the Trust) is a Delaware statutory trust, formed on June 6, 2025, pursuant to the Delaware
Statutory Trust Act. The Trust continuously issues common shares representing fractional undivided beneficial interest in and ownership
of the Trust that may be purchased and sold on the Nasdaq Stock Market, LLC (the Exchange) under the symbol SOLC.
The Trust operates pursuant to a Trust Agreement, as amended and/or restated from time to time (the Trust Agreement). CSC
Delaware Trust Company, a Delaware trust company, is the trustee of the Trust (the Trustee). The Trust is managed and controlled
by Canary Capital Group LLC (the Sponsor).
The
Trust is an exchange-traded fund that issues shares of beneficial interest (the Shares) that are listed and trade on the
Exchange. The Trusts investment objective is to seek to provide exposure to the price of Solana (SOL) held by the
Trust, less the expenses of the Trusts operations and other liabilities. A secondary investment objective is for the Trust to
earn additional SOL through the validation of transactions in the SOL networks (the Solana Network) proof-of-stake
(PoS) process. In seeking to achieve its investment objectives, the Trust will hold SOL and establish its net asset value
(NAV) on each business day by reference to the CoinDesk Solana CCIXber 60m New York Rate (the Pricing Benchmark).
The Pricing Benchmark is calculated by CoinDesk Indices (the Benchmark Provider) based on a 60-minute time-weighted average
price of the SOL-USD CCIXber Reference Rate (the Underlying Index), which is an aggregation of executed trade flow of major
SOL trading platforms (Constituent Platforms). The Benchmark Provider publishes the Pricing Benchmark. The Trust is sponsored
by the Sponsor.
| 
2. | Significant
Accounting Policies | |
*Basis
of Presentation*
The
following is a summary of significant accounting policies consistently followed by the Trust in the preparation of these financial statements.
The accompanying financial statements have been prepared in conformity with accounting principles generally accepted in the United States
of America (GAAP) and are stated in U.S. dollars. The Trusts financial statements were prepared using the accounting
and reporting guidance of the Financial Accounting Standards Board (FASB) Accounting Standards Codification (ASC)
Topic 946, Financial Services Investment Companies. The Trust qualifies as an investment company solely for accounting purposes
and not for any other purpose. The Trust is not registered, and is not required to be registered, as an investment company under the
Investment Company Act of 1940, as amended. The Trust follows the significant accounting policies described below.
36
*Use
of Estimates*
The
preparation of the financial statements in conformity with GAAP requires management to make estimates and assumptions that affect the
reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements.
Actual results could differ from those estimates.
*Cash*
Generally,
the Trust does not intend to hold any cash. Cash includes non-interest bearing non-restricted cash with one institution. Cash in a bank
deposit account, at times, may exceed U.S. federally insured limits. The Trust has not experienced any losses in such accounts and does
not believe it is exposed to any significant credit risk on such bank deposits.
*Investment
Transactions and Investment Income*
The
Trust purchases SOL upon the creation of Shares and sells SOL upon the redemption of Shares. Transactions are recorded on a trade-date
basis. Realized gains (losses) and changes in unrealized gains (losses) on open positions are determined on a specific identification
basis and recognized in the statement of operations in the period in which the sale occurred or the changes in unrealized occurred.
*Income
Taxes*
The
Sponsor takes the position that the Trust is properly treated as a grantor trust for U.S. federal income tax purposes. Assuming that
the Trust is a grantor trust, the Trust will not be subject to U.S. federal income tax. Rather, if the Trust is a grantor trust, each
beneficial owner of Shares will be treated as directly owning its pro rata Share of the Trusts assets and a pro rata portion of
the Trusts income, gains, losses and deductions will flow through to each beneficial owner of Shares. If the Trust
were not properly classified as a grantor trust, the Trust might be classified as a partnership for U.S. federal income tax purposes.
However, due to the uncertain treatment of digital assets, with respect to staking and including forks, airdrops and similar occurrences
for U.S. federal income tax purposes, there can be no assurance in this regard. If the Trust were classified as a partnership for
U.S.
federal income tax purposes, the tax consequences of owning Shares generally would not be materially different from the tax consequences
described herein, although there might be certain differences, including with respect to timing. In addition, tax information reports
provided to beneficial owners of Shares would be made in a different form. If the Trust were not classified as either a grantor trust
or a partnership for U.S. federal income tax purposes, it would be classified as a corporation for such purposes. In that event, the
Trust would be subject to entity-level U.S. federal income tax (currently at the rate of 21%) on its net taxable income and certain distributions
made by the Trust to shareholders would be treated as taxable dividends to the extent of the Trusts current and accumulated earnings
and profits.
37
*Digital
Asset Trading Platform Valuation*
US
GAAP defines fair value as the price the Trust would receive to sell an asset or pay to transfer a liability in an orderly transaction
between market participants at the measurement date. The Trusts policy is to value investments held at fair value.
The
Trust identifies and determines the SOL principal market (or in the absence of a principal market, the most advantageous market)
for GAAP purposes consistent with the application of the fair value measurement framework in FASB ASC 820 Fair Value Measurement.
A principal market is the market with the greatest volume and activity level for the asset or liability. The determination of the principal
market will be based on the market with the greatest volume and level of activity that can be accessed. The Trust obtains relevant volume
and level of activity information and based on initial analysis will select an exchange market as the Trusts principal market.
The net asset value (NAV) and NAV per Share will be calculated using the fair value of SOL based on the price
provided by this exchange market, as of 4:00 p.m. ET on the measurement date for GAAP purposes. The Trust will update its principal market
analysis periodically and as needed to the extent that events have occurred, or activities have changed in a manner that could change
the Trusts determination of the principal market.
Various
inputs are used in determining the fair value of assets and liabilities. Inputs may be based on independent market data (observable
inputs) or they may be internally developed (unobservable inputs). These inputs are categorized into a disclosure
hierarchy consisting of three broad levels for financial reporting purposes. The level of a value determined for an asset or liability
within the fair value hierarchy is based on the lowest level of any input that is significant to the fair value measurement in its entirety.
The three levels of the fair value hierarchy are as follows:
Level
1: Unadjusted quoted prices in active markets for identical assets or liabilities;
Level
2: Inputs other than quoted prices included within Level 1 that are observable for the asset or liability either directly or indirectly,
including quoted prices for similar assets or liabilities in active markets, quoted prices for identical or similar assets or liabilities
in markets that are not considered to be active, inputs other than quoted prices that are observable for the asset or liability, and
inputs that are derived principally from or corroborated by observable market data by correlation or other means; and
Level
3: Unobservable inputs, including the Trusts assumptions used in determining the fair value of investments, where there is little
or no market activity for the asset or liability at the measurement date.
The
following table presents information about the Trusts assets measured at fair value as of December 31, 2025:
| 
| | 
Level 1 | | | 
Level 2 | | | 
Level 3 | | | 
Total | | |
| 
Investments: | | 
| | | 
| | | 
| | | 
| | |
| 
SOL | | 
$ | 1,926,808 | | | 
$ | | | | 
$ | | | | 
$ | 1,926,808 | | |
| 
Total Investments | | 
$ | 1,926,808 | | | 
$ | | | | 
$ | | | | 
$ | 1,926,808 | | |
38
There
were no transfers between levels for the period ended December 31, 2025.
The
following represents the changes in quantity of SOL and the respective fair value:
| 
| | 
SOL | | | 
Fair Value | | |
| 
Beginning balance as of November 17, 2025 | | 
| | | | 
$ | | | |
| 
SOL purchased | | 
| 15,506 | | | 
| 2,096,032 | | |
| 
SOL contributed in-kind for the creation of Shares | | 
| | | | 
| | | |
| 
SOL distributed in-kind for the redemption of Shares | | 
| | | | 
| | | |
| 
Net change in unrealized appreciation (depreciation) in SOL | | 
| | | | 
| (169,224 | ) | |
| 
Net realized gain (loss) on investment in SOL | | 
| | | | 
| | | |
| 
Ending balance as of December 31, 2025 | | 
| 15,506 | | | 
$ | 1,926,808 | | |
*Calculation
of NAV*
The
Administrator, defined below, determines the NAV of the Trust on each day that the Exchange is open for regular trading, as promptly
as practicable after 4:00 p.m. ET. The NAV of the Trust is the aggregate value of the Trusts assets less its accrued but unpaid
liabilities (which include accrued expenses). In determining the Trusts NAV, the Administrator values SOL held by the Trust based
on the price set by the Index as of 4:00 p.m. ET. The Administrator also determines the NAV per Share. For purposes of the Trusts
financial statements, the Trust utilizes a pricing source that is consistent with GAAP, as of the financial statement measurement date,
which may result in valuations that differ from the Trusts daily NAV calculations. The Sponsor determines in its sole discretion
the valuation sources and policies used to prepare the Trusts financial statements in accordance with GAAP.
The
Trusts NAV per Share is calculated by taking the current fair value of its total assets, subtracting any liabilities, and dividing
that total by the number of Shares.
*Segment
Reporting*
The
Trust operates through a single operating and reporting segment with a primary objective of providing exposure to the price of SOL held
by the Trust, less the expenses of the Trusts operations and other liabilities. The Trusts chief operating decision maker
(CODM) is the Principal Executive Officer. The CODM monitors the operating results of the Trust and the Trusts long-term
strategic asset allocation is predetermined in accordance with the terms of its prospectus, based on the defined investment strategy
against which the CODM assesses the Trusts performance. In addition to other metrics, the CODM uses net increase (decrease) in
net assets resulting from operations as a key metric to assess the Trusts performance.
| 
3. | Trust
Expenses and Other Agreements | |
| 
(a) | Sponsor | |
**
The
Trust pays the Sponsor an annual unified fee of 0.50% of the Trusts SOL Holdings (the Sponsor Fee). The
Trusts SOL Holdings is the quantity of the Trusts SOL plus any cash or other assets held by the Trust
represented in SOL as calculated using the Index Price, less its liabilities (which include estimated accrued but unpaid fees and
expenses) represented in SOL as calculated using the Index Price. The Sponsor Fee is paid by the Trust to the Sponsor as
compensation for services performed under the Trust Agreement. The Administrator calculates the Sponsor Fee in respect of each day
by reference to the prior days SOL Holdings. Except for periods during which all or a portion of the Sponsor Fee is being
waived, the Sponsor Fee accrues daily in SOL and is payable monthly in SOL or cash. To the extent there are any on-chain transaction
fees incurred in connection with the transfers of SOL to pay the Sponsor Fee, the Sponsor, and not the Trust, shall bear such fees.
The Sponsor may, at its sole discretion and from time to time, waive all or a portion of the Sponsor Fee for stated periods of time.
The Sponsor is under no obligation to waive any portion of its fees, and any such waiver shall create no obligation to waive any
such fees during any period not covered by the waiver.
39
The
Sponsor agreed to waive the Sponsor Fee in its entirety until the earlier of: (1) the Federal Reserve's Federal Open Market Committee
establishing a target range for the Federal Funds Rate that includes or is lower than 3.00%; or (2) July 1, 2026. For the period ended
December 31, 2025, the Trust incurred $969 in Sponsor Fees, of which, $969 was waived by the Sponsor, as presented on the Statement of
Operations.
As
partial consideration for its receipt of the Sponsor Fee, the Sponsor is obligated under the Trust Agreement to assume and pay all
fees and other expenses incurred by the Trust in the ordinary course of its affairs, excluding taxes, but including: (i) the fees of
the Trusts third-party service providers, including, but not limited to, the Marketing Agent, the Administrator, the
Custodian, the Transfer Agent, the Cash Custodian, the Index Provider, and the Trustee, (ii) the fees and expenses related to the
listing, quotation or trading of the Shares on the Exchange (including customary legal, marketing and audit fees and expenses),
(iii) legal fees and expenses incurred in the ordinary course, (iv) audit fees, (v) regulatory fees, including, if applicable, any
fees relating to the registration of the Trust and Shares, including any ongoing filings related to the offering of Shares, under
the 1933 Act or the 1934 Act, (vi) printing and mailing costs, (vii) costs of maintaining the Trusts website and (viii)
applicable license fees (each, a Sponsor-paid Expense and collectively, the Sponsor-paid Expenses),
provided that any expense that qualifies as an Extraordinary Expense (as defined below) will not be deemed to be a Sponsor-paid
Expense. There is no cap on the amount of Sponsor-paid Expenses. The Sponsor has also assumed all fees and expenses related to the
organization and offering of the Trust and the Shares.
The
Trust may incur certain extraordinary, nonrecurring expenses that are not Sponsor-paid Expenses, including, but not limited to,
brokerage and transaction costs associated with the sale or transfer of SOL, taxes and governmental charges, expenses and costs of
any extraordinary services performed by the Sponsor (or any other service provider) on behalf of the Trust to protect the Trust, the
Trusts assets, or the interests of Shareholders, any indemnification of the Custodian or other agents, service providers or
counterparties of the Trust, and extraordinary legal fees and expenses, including any legal fees and expenses incurred in connection
with litigation, regulatory enforcement or investigation matters (collectively, Extraordinary Expenses). To the extent
on-chain transaction fees are incurred in connection with transfers or sales of SOL to pay Extraordinary Expenses, the Trust will
bear such fees, but to the extent there are any on-chain transaction fees incurred in connection with the transfers of SOL to pay
the Sponsor Fee or any Sponsor-paid Expenses, the Sponsor, and not the Trust, shall bear such fees.
40
To
the extent it does not have cash readily available, the Sponsor will cause the transfer or sale of SOL in such quantity as may be necessary
to permit the payment of Trust expenses and liabilities not assumed by the Sponsor or for payment of cash redemption proceeds to Authorized
Participants (as defined below). The Trust will seek to transfer or sell SOL at such times and in the smallest amounts required to permit
such payments as they become due. With respect to transfers or sales necessary to pay Trust expenses and liabilities that are denominated
other than in SOL, the amount of SOL transferred or sold may vary from time to time depending on the actual sales price of SOL relative
to the Trusts expenses and liabilities (e.g., if the price of SOL falls, the amount of SOL needed to be transferred or sold to
pay an expense or liability denominated in U.S. dollars will increase). To the extent the Trust must buy or sell SOL, the Trust may do
so through a third-party digital asset broker or dealer. The Sponsor will select third party brokers or dealers that it believes have
implemented adequate AML, KYC and other legal compliance policies and procedures.
Under
the terms of each Authorized Participant Agreement, the Authorized Participants will be responsible for any brokerage or transaction
costs associated with the sale or transfer of SOL incurred in connection with the fulfillment of a creation or redemption order.
| 
(b) | Administrator,
Custodian and Transfer Agent | |
**
U.S.
Bancorp Fund Services, LLC, doing business as U.S. Bank Global Fund Services (the Administrator and Transfer Agent)
serves as administrator, transfer agent and accounting agent of the Trust pursuant to a Fund Servicing Agreement. BitGo Trust Company,
Inc. (the Custodian) serves as the Trusts SOL Custodian. Under the BitGo Custodial Services Agreement, the Custodian
is responsible for safekeeping all the Trusts SOL. The Custodian was selected by the Sponsor. The Sponsor is responsible for opening
accounts with the Custodian that hold the Trusts SOL (the SOL Accounts), as well as facilitating the transfer or
sale of SOL required for the operation of the Trust.
U.S.
Bank, N.A., an affiliate of the Administrator and Transfer Agent serves as the cash custodian for the Trust (the Cash Custodian).
The Cash Custodian is responsible for safekeeping all cash and other non-SOL assets of the Trust.
| 
(c) | Marketing
Agent | |
**
Paralel
Distributors LLC is the marketing agent of the Trust (the Marketing Agent) and is responsible for reviewing and approving
the marketing materials, including the Trusts website, prepared by the Sponsor for compliance with applicable SEC and Financial
Industry Regulatory Authority, Inc. (FINRA) advertising laws, rules, and regulations pursuant to a marketing agreement
with the Trust. The Marketing Agent is a broker-dealer registered under the Securities Exchange Act of 1934, as amended (the Exchange
Act) and a member of FINRA. With the assistance of the Marketing Agent, the Sponsor developed a marketing plan for the Trust,
prepared marketing materials regarding the Shares of the Trust, and exercises the marketing plan of the Trust on an ongoing basis.
41
| 
(d) | Principal
Financial Officer | |
**
Employees
of PINE Advisors LLC (PINE) serve as officers of the Trust. In consideration for these services, the Sponsor pays PINE
an annual fee. The Sponsor also reimburses PINE for certain out-of-pocket expenses.
| 
4. | Capital
Share Transactions | |
****
The
Trust is an exchange-traded product. The Trust issues Shares on a continuous basis and, when the Trust creates or redeems its Shares,
it does so in blocks of 10,000 Shares (a Basket) based on the quantity of SOL attributable to each Share of the Trust (net
of accrued but unpaid expenses and liabilities). Certain financial firms are authorized to purchase or redeem Shares of the Trust (Authorized
Participants).
The
manner by which creations are made is dictated by the terms of the Authorized Participant Agreement. Creation orders may be denominated
and settled in an amount of SOL (In-Kind Creation Order) or in cash (Cash Creation Order). By placing an
In-Kind Creation Order, an Authorized Participant agrees to facilitate the deposit of SOL with the Custodian, either directly or indirectly
through an Authorized Participant Designee. By placing a Cash Creation Order, an Authorized Participant agrees to facilitate the deposit
of cash with the Cash Custodian. An Authorized Participant may not withdraw a creation order without the prior consent of the Sponsor
in its discretion.
The
manner by which redemptions are made is dictated by the terms of the Authorized Participant Agreement. Redemption orders are denominated
and settled either in-kind (In-Kind Redemption Order) or in cash (Cash Redemption Order). By placing a redemption
order, an Authorized Participant agrees to facilitate the deposit of Shares with the Transfer Agent. If an Authorized Participant fails
to consummate the foregoing, the order will be cancelled or delayed until the required Shares have been received. An Authorized Participant
may not withdraw a redemption order without the prior consent of the Sponsor in its discretion.
Shares
initially comprising the same Basket but offered by the Authorized Participants to the public at different times may have different offering
prices, which depend on various factors, including the supply and demand for Shares, the value of the Trusts assets, and market
conditions at the time of a transaction. Shareholders who buy or sell Shares during the day from their broker may do so at a premium
or discount relative to the NAV of the Shares of the Trust.
Shareholders
who decide to buy or sell Shares of the Trust place their trade orders through their brokers and incur customary brokerage commissions
and charges.
Only
Authorized Participants may place orders to create and redeem baskets through the Transfer Agent. The Transfer Agent coordinates with
the Trusts custodian to facilitate settlement of the Shares.
42
Activity
in the number and value of Shares created and redeemed for the period ended December 31, 2025 are as follows:
| 
| | 
Number of Shares | | | 
Value of Shares | | |
| 
Creations | | 
| 80,000 | | | 
$ | 2,085,701 | | |
| 
Redemptions | | 
| | | | 
| | | |
| 
Net change in Shares created and redeemed | | 
| 80,000 | | | 
$ | 2,085,701 | | |
| 
5. | 
Financial Highlights | 
|
The
Trust is presenting the following financial highlights related to investment performance and operations of a Share outstanding for the
period from November 17, 2025 (the initial share purchase date) through December 31, 2025. As the Trust had not yet commenced operations
before this period, no comparative period is presented. The total return at NAV is based on the change in NAV of a Share during the period,
and the total return at market value is based on the change in market value of a Share on the Exchange during the period. An individual
investors return and ratios may vary based on the timing of capital transactions.
For
the period November 17, 2025 (initial share purchase date) through December 31, 2025:
| 
| | 
| | | |
| 
Net Asset Value, Beginning of Period | | 
$ | 25.00 | | |
| 
Net investment income (loss)(1) | | 
| 0.16 | | |
| 
Net Realized and Unrealized Gain (Loss) on
Investments(2) | | 
| (1.07 | ) | |
| 
Net Increase (Decrease) in Net Asset Value Resulting from Operations | | 
| (0.91 | ) | |
| 
Net Asset Value, End of Period | | 
$ | 24.09 | | |
| 
Market Value Per Share, at December 31, 2025(3) | | 
$ | 24.06 | | |
| 
Total Return at Net Asset Value(4) | | 
| -3.69 | % | |
| 
Total Return at Market Value(3)(4) | | 
| -3.78 | % | |
| 
Ratios to Average Net Assets:(5) | | 
| | | |
| 
Expense ratio before expense waiver(5) | | 
| 0.50 | % | |
| 
Expense ratio after expense waiver(5) | | 
| 0.00 | % | |
| 
Net Investment Income (Loss) before expense waiver(5) | | 
| 4.83 | % | |
| 
Net Investment Income (Loss) after expense waiver(5) | | 
| 5.33 | % | |
| 
(1) | Net investment
loss per share represents net investment loss divided by the daily average shares of beneficial interest outstanding during the period. | 
|
| 
(2) | Due to timing of
capital share transactions, per share amounts may not compare with amounts appearing elsewhere within these Financial Statements. | 
|
| 
(3) | Market values are
determined at the close of the applicable primary listing exchange, which may be later than when the Fund's net asset value is calculated. | 
|
| 
(4) | Not Annualized. | 
|
| 
(5) | Annualized. | 
|
| 
6. | Related
Parties | |
****
The
Sponsor is considered to be a related party to the Trust. The Trust's operations are supported by its Sponsor. As of December 31, 2025,
the Sponsor did not own any Shares of the Trust.
43
| 
7. | Commitments
and Contingent Liabilities | |
****
In
the normal course of business, the Trust may enter into contracts that contain a variety of general indemnification clauses. The Trusts
maximum exposure under these arrangements is unknown as this would involve future claims that may be made against the Trust which have
not yet occurred and cannot be predicted with any certainty. However, the Sponsor believes the risk of loss under these arrangements
to be remote. There were no commitments or contingencies required to be disclosed as of the date of the financial statements.
| 
8. | SOL
Staking | |
****
Under
normal circumstances, the Sponsor will seek to stake all of the Trusts SOL through one or more staking providers (each, a Staking
Provider) except for SOL reserved by the Sponsor in its sole discretion to facilitate foreseeable redemption transactions, pay
Trust expenses or otherwise protect the Trust and its assets. In consideration for any staking activity in which the Trust may engage,
the Trust will receive a portion of the staking rewards generated by a Staking Provider. The Staking Provider for the Trusts
SOL is Sous Vide Ltd. (Marinade Finance).
The
Trust earns staking rewards by delegating a portion of its SOL on the Solana Networks proof-of-stake consensus protocol. The Trust
will stake the Trusts SOL on the Solana Network through the Custodian using a software protocol provided by Marinade Finance that
connects the Trust to a pool of verified validator nodes on the Solana Network for automated SOL staking optimization. As a result of
any staking activity in which the Trust may engage, the Trust expects to receive certain staking rewards of SOL, which may be treated
for federal income tax purposes as income to the Trust. The Trust itself will not engage in staking activities, including operation of
a validator node. Instead, the staking program will be operated through the Trusts service providers, including the Custodian
and Staking Provider. The Staking Provider exercises no discretion as to the amount the Trusts SOL to be staked or timing of the
staking activities. The Custodian will maintain exclusive possession and control of the private keys associated with any staked SOL at
all times. As of December 31, 2025, 15,503 SOL were staked, representing a fair value of $1,926,423, which is included in Investments,
at fair value on the Statement of Assets and Liabilities.
Staking
rewards represent variable consideration, as the amount of rewards is not known until the applicable validation activities are
completed, and the Trust receives rewards in their custodial account. The contract term is the length of each staking epoch. The
staking epoch for the Solana Network is approximately two days. Staking rewards are recognized as income when the Trust satisfies
its performance obligations (i.e., successfully validates blocks or transactions as determined by the protocol) ratably over the
contract term. Staking rewards are received in SOL, which represents non-cash consideration. Non-cash consideration is measured at
fair value at the inception of each contract (i.e., the beginning of each staking epoch). Because the Trust is not the principal to
the block validation service, it does not control the full output of the reward-generating activity, and instead receives net
staking rewards, after Validator Fees are deducted. As such, the Trust presents staking income on a net basis, reflecting only the
portion of protocol rewards to which it is entitled. For the period ended December 31, 2025, the Trust generated $10,331 in staking
income, as presented on the Statement of Operations.
| 
9. | Subsequent
Events | |
****
The
Sponsor has evaluated subsequent events through the date the financial statements were issued. Based on this evaluation, no adjustments
or disclosures to the financial statements were required.
44
Item
9. Changes in and Disagreements With Accountants on Accounting and Financial Disclosure.
****
Not
applicable.
Item
9A. Controls and Procedures.
Disclosure
Controls and Procedures
The
Trust maintains disclosure controls and procedures that are designed to ensure that information required to be disclosed in its 1934
Act reports is recorded, processed, summarized and reported within the time periods specified in the SECs rules and forms, and
that such information is accumulated and communicated to the Principal Executive Officer and Principal Financial Officer of the Sponsor
to allow timely decisions regarding required disclosure.
Under
the supervision and with the participation of the Principal Executive Officer and the Principal Financial and Accounting Officer of the
Sponsor, the Sponsor conducted an evaluation of the Trust's disclosure controls and procedures, as defined under Exchange Act Rule 13a-15(e).
Based on this evaluation, the Principal Executive Officer and the Principal Financial and Accounting Officer of the Sponsor concluded
that, as of December 31, 2025, the Trusts disclosure controls and procedures were effective.
Managements
Annual Report on Internal Control Over Financial Reporting
****
The
Sponsors management is responsible for establishing and maintaining adequate internal control over financial reporting, as defined
under Exchange Act Rules 13a-15(f) and 15d-15(f). The Trusts internal control over financial reporting is a process designed to
provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external
purposes in accordance with accounting principles generally accepted in the United States. Internal control over financial reporting
includes those policies and procedures that: (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly
reflect the transactions and dispositions of the Trusts assets, (2) provide reasonable assurance that transactions are recorded
as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that the
Trusts receipts and expenditures are being made only in accordance with appropriate authorizations; and (3) provide reasonable
assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the Trusts assets that
could have a material effect on the financial statements.
Because
of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of
any evaluation of effectiveness to future periods are subject to the risk that controls may become ineffective because of changes in
conditions, or that the degree of compliance with the policies or procedures may deteriorate.
The
Principal Executive Officer and Principal Financial and Accounting Officer of the Sponsor assessed the effectiveness of the Trusts
internal control over financial reporting as of December 31, 2025. In making this assessment, they used the criteria set forth by the
Committee of Sponsoring Organizations of the Treadway Commission (COSO) in Internal ControlIntegrated Framework (2013). Their
assessment included an evaluation of the design of the Trusts internal control over financial reporting and testing of the operational
effectiveness of its internal control over financial reporting. Based on their assessment and those criteria, the Principal Executive
Officer and Principal Financial and Accounting Officer of the Sponsor concluded that the Trust maintained effective internal control
over financial reporting as of December 31, 2025.
Changes
in Internal Control over Financial Reporting
****
There
were no changes in the Trusts internal control over financial reporting that occurred during the period ended December 31, 2025
that have materially affected, or are reasonably likely to materially affect, the Trusts internal control over financial reporting.
Item
9B. Other Information.
****
Not
applicable.
Item
9C. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections.
****
Not
applicable.
45
PART
III
****
Item
10. Directors, Executive Officers and Corporate
Governance. The Sponsor
The
Trust does not have any directors, officers or employees. The creation and operation of the Trust have been arranged by the Sponsor.
Background
and Principals
****
*Steven
McClurg Chief Executive Officer*
**
Steven
McClurg has considerable finance and fintech experience. Most recently, Mr. McClurg served as the Chief Investment Officer of Valkyrie
Investments. Mr. McClurg also founded Theseus Capital, a Blockchain-powered asset management platform, followed by joining Blockchain-focused
merchant bank, Galaxy Digital, where he continued as Managing Director, building their asset management and public funds businesses.
Most relevant, Mr. McClurg was a Managing Director at Guggenheim Partners, where he was a portfolio manager and responsible for portfolio
construction and strategy for fixed income and private equity. He also has experience in leadership roles in technology companies such
as Electronic Arts. Mr. McClurg holds a Master of Science and an MBA from Pepperdine University, where he has served as an adjunct professor.
Mr. McClurg is the Principal Executive Officer of the Trust.
*Drew
Hill President*
**
Drew
Hill is an experienced attorney specializing in blockchain, token and cryptocurrency law, with a focus on securities law and regulatory
compliance for public and private funds. Previously, Mr. Hill served as General Counsel and Chief Compliance Officer at Valkyrie Investments,
where he led the legal and compliance teams and played a key role in launching digital asset themed ETFs, including the spot Bitcoin
ETF BRRR and the bitcoin miners ETF WGMI. Prior to his tenure at Valkyrie Investments, Mr. Hill was a key
member of the nationally recognized Blockchain Practice at Frost Brown Todd LLC, advising clients on mergers and acquisitions, private
fund formation, start-up fundraising and securities law compliance for token and cryptocurrency issuers. Mr. Hill currently serves as
President and Chief Legal Officer of Canary Capital Group. Mr. Hill holds a Bachelor of Arts in Finance and Spanish from the Clark Honors
College at the University of Oregon and a Juris Doctor from Northwestern University Pritzker School of Law.
*Starr
Frohlich Principal Financial Officer and Principal Accounting Officer*
**
Starr
Frohlich has extensive experience in finance and investment management. Ms. Frohlich currently serves as a Director on the Principal
Financial Officer Services team at PINE Advisor Solutions, where she acts as Principal Financial Officer and Treasurer for registered
fund products, overseeing financial, accounting and regulatory reporting functions. Previously, Ms. Frohlich was Vice President at JPMorgan
Chase & Co., where she supervised financial reporting and regulatory filings for a wide range of registered investment companies.
Earlier in her career, she was Vice President and Treasurer of AssetMark, Inc.'s proprietary registered funds, and she also held a senior
fund administration and financial reporting position at U.S. Bank Global Fund Services. Ms. Frohlich serves as the Principal Financial
Officer and the Principal Accounting Officer of the Trust. Ms. Frohlich holds a Bachelor of Science in Accounting from the University
of Minnesota and is a Certified Public Accountant.
Family
Relationships
****
There
are no family relationships among our executive officers.
Indemnification
****
The
general fiduciary duties that would otherwise be imposed on the Sponsor (which would make its operation of the Trust as described herein
impracticable due to the strict prohibition imposed by such duties on, for example, conflicts of interest on behalf of a fiduciary in
its dealings with its beneficiaries), are replaced entirely by the terms of the Trust Agreement (to which terms all Shareholders, by
subscribing to the Shares, are deemed to consent).
The
Trust Agreement provides that the Trust shall indemnify, defend and hold harmless the Trustee (including in its individual capacity)
and any of the officers, directors, employees and agents of the Trustee (the Indemnified Persons) from and against any
and all losses, damages, liabilities, claims, actions, suits, costs, expenses, disbursements (including the reasonable fees and expenses
of counsel and fees and expenses incurred in connection with enforcement of its indemnification rights under the Trust Agreement), taxes
and penalties of any kind and nature whatsoever (collectively, Expenses), to the extent that such Expenses arise out of
or are imposed upon or asserted at any time against such Indemnified Persons with respect to the performance of the Trust Agreement,
the creation, operation or termination of the Trust or the transactions contemplated thereby; provided, however, that the Trust shall
not be required to indemnify any Indemnified Person for any Expenses which are a result of the willful misconduct, bad faith or gross
negligence of an Indemnified Person. If the Trust shall have insufficient assets or improperly refuses to pay an Indemnified Person within
sixty (60) days of a request for payment owed hereunder, the Sponsor shall, as secondary obligor, compensate or reimburse the Trustee
or indemnify, defend and hold harmless an Indemnified Person as if it were the primary obligor under the Trust Agreement; provided, however,
that the Sponsor shall not be required to indemnify any Indemnified Person for any Expenses which are a result of the willful misconduct,
bad faith or gross negligence of an Indemnified Person. To the fullest extent permitted by law and by the requirement for treatment of
the Trust as a grantor trust for tax purposes, Expenses to be incurred by an Indemnified Person shall, from time to time, be advanced
by, or on behalf of, the Sponsor prior to the final disposition of any matter upon receipt by the Sponsor of an undertaking by, or on
behalf of, such Indemnified Person to repay such amount if it shall be determined that the Indemnified Person is not entitled to be indemnified
under this Trust Agreement.
46
Under
Delaware law, a beneficial owner of a statutory trust (such as a shareholder of the Trust) may, under certain circumstances, institute
legal action on behalf of himself and all other similarly situated beneficial owners (a class action) to recover damages
for violations of fiduciary duties, or on behalf of a statutory trust (a derivative action) to recover damages from a third
party where there has been a failure or refusal to institute proceedings to recover such damages. In addition, beneficial owners may
have the right, subject to certain legal requirements, to bring class actions in federal court to enforce their rights under the federal
securities laws and the rules and regulations promulgated thereunder by the SEC. Beneficial owners who have suffered losses in connection
with the purchase or sale of their beneficial interests may be able to recover such losses from the Sponsor where the losses result from
a violation by the Sponsor of the anti-fraud provisions of the federal securities laws.
The
foregoing summary describing in general terms the remedies available to shareholders under federal law is based on statutes, rules and
decisions as of the date of this Annual Report. As this is a rapidly developing and changing area of the law, shareholders who believe
that they may have a legal cause of action against any of the foregoing parties should consult their own counsel as to their evaluation
of the status of the applicable law at such time.
Code
of Ethics
****
The
Trust has not adopted a code of ethics (Code of Ethics) as it is not required to do so under applicable laws, rules and
regulations.
Insider
Trading Policies and Procedures
****
Because
the Trust does not have directors, officers, or employees, it has not adopted insider trading policies and procedures governing the purchase,
sale and/or disposition of Trust securities by such persons.
Item
11. Executive Compensation.
****
The
Trust has no employees or directors and is managed by the Sponsor. None of the officers of the Trust, or the members or officers of the
Sponsor receive compensation from the Trust.
The
Sponsor is entitled to receive a Sponsors Fee from the Trust equal to a unified fee of 0.50% of the Trusts SOL Holdings.
During
the fiscal period ended December 31, 2025, the Sponsor elected to waive all sponsor fees.
Item
12. Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters.
****
Not
applicable.
Item
13. Certain Relationships and Related Transactions, and Director Independence.
****
*Sponsor
Agreement*
The
Trust pays the Sponsor an annual unified fee of 0.50% of the Trusts SOL Holdings (the Sponsor Fee). The Trusts
SOL Holdings is the quantity of the Trusts SOL plus any cash or other assets held by the Trust represented in SOL
as calculated using the Pricing Benchmark price, less its liabilities (which include estimated accrued but unpaid fees and expenses)
represented in SOL as calculated using the Pricing Benchmark price. The Sponsor Fee is paid by the Trust to the Sponsor as compensation
for services performed under the Trust Agreement. The Administrator calculates the Sponsor Fee in respect of each day by reference to
the prior days SOL Holdings. Except for periods during which all or a portion of the Sponsor Fee is being waived, the Sponsor
Fee accrues daily in SOL and is payable monthly in SOL or cash. To the extent there are any on-chain transaction fees incurred in connection
with the transfers of SOL to pay the Sponsor Fee, the Sponsor, and not the Trust, shall bear such fees. The Sponsor may, at its sole
discretion and from time to time, waive all or a portion of the Sponsor Fee for stated periods of time. The Sponsor is under no obligation
to waive any portion of its fees and any such waiver shall create no obligation to waive any such fees during any period not covered
by the waiver.
As
partial consideration for its receipt of the Sponsor Fee, the Sponsor is obligated under the Trust Agreement to assume and pay all fees
and other expenses incurred by the Trust in the ordinary course of its affairs, excluding taxes, but including: (i) the fees of the Trusts
third-party service providers including, but not limited to, the Marketing Agent, the Administrator, the Custodian, the Cash Custodian,
the Transfer Agent, the Benchmark Provider, and the Trustee, (ii) the fees and expenses related to the listing, quotation or trading
of the Shares on the Exchange (including customary legal, marketing and audit fees and expenses), (iii) legal fees and expenses incurred
in the ordinary course, (iv) audit fees, (v) regulatory fees, including, if applicable, any fees relating to the registration of the
Trust and Shares, including any ongoing filings related to the offering of Shares, under the 1933 Act or the 1934 Act, (vi) printing
and mailing costs, (vii) costs of maintaining the Trusts website and (viii) applicable license fees (each, a Sponsor-paid
Expense and collectively, the Sponsor-paid Expenses), provided that any expense that qualifies as an Extraordinary
Expense (as defined below) is not deemed to be a Sponsor-paid Expense. There is no cap on the amount of Sponsor-paid Expenses. The Sponsor
has also assumed all fees and expenses related to the organization and offering of the Trust and the Shares.
47
The
Trust may incur certain extraordinary, nonrecurring expenses that are not Sponsor-paid Expenses, including, but not limited to, brokerage
and transaction costs associated with the sale or transfer of SOL, taxes and governmental charges, expenses and costs of any extraordinary
services performed by the Sponsor (or any other service provider) on behalf of the Trust to protect the Trust, the Trusts assets,
or the interests of Shareholders, any indemnification of the Custodians or other agents, service providers or counterparties of the Trust,
and extraordinary legal fees and expenses, including any legal fees and expenses incurred in connection with litigation, regulatory enforcement
or investigation matters (collectively, Extraordinary Expenses). To the extent on-chain transaction fees are incurred in
connection with transfers or sales of SOL to pay Extraordinary Expenses, the Trust bears such fees.
To
the extent it does not have cash readily available, the Sponsor shall cause the transfer or sale of SOL in such quantity as may be necessary
to permit the payment of Trust expenses and liabilities not assumed by the Sponsor or for payment of redemption proceeds to Authorized
Participants. The Trust does not bear any costs associated with the transfer or sale of SOL to pay the Sponsor Fee. To the extent the
Trust incurs any Extraordinary Expenses, the Trust bears the costs of any transfers or sales of SOL to pay such expenses. The Trust seeks
to transfer SOL at such times and in the smallest amounts required to permit such payments as they become due. With respect to transfers
or sales necessary to pay Trust expenses and liabilities that are denominated other than in SOL, the amount of SOL transferred or sold
may vary from time to time depending on the actual sales price of SOL relative to the Trusts expenses and liabilities (*e.g.*,
if the price of SOL falls, the amount of SOL needed to be transferred or sold to pay an expense denominated in U.S. dollars will increase).
To the extent the Trust must buy or sell SOL, the Trust may do so through a third-party digital asset broker or dealer. When the Trust
buys or sells SOL, the Sponsor seeks quotes from its SOL trading counterparties. Such transactions are typically conducted over the counter
rather than over a trading platform or similar order matching service. The Sponsor selects third party brokers or dealers that it believes
have implemented adequate AML, KYC and other legal compliance policies and procedures.
Under
the terms of each Authorized Participant Agreement, the Authorized Participants are responsible for any brokerage or transaction costs
associated with the sale or transfer of SOL incurred in connection with the fulfillment of a creation or redemption order.
*Director
Independence*
**
The
Trust does not have any directors, officers or employees. The creation and operation of the Trust have been arranged by the Sponsor.
Item
14. Principal Accounting Fees and Services.
****
(1)
to (4). Fees for services performed by Cohen
& Company, Ltd. (Cohen & Co) for the period ended December 31, 2025 were as follows:
ID: 925
| 
| | 
Period Ended 
December 31, 
2025 | 
|
| 
Audit Fees | | 
$ | 60,000 | | 
|
| 
Audit-Related Fees | | 
| - | | 
|
| 
Tax Fees | | 
| - | | 
|
| 
All Other Fees | | 
| - | | 
|
| 
Total | | 
$ | 60,000 | | 
|
(5)
The Sponsor approved all of the services provided by Cohen & Co described above. The Sponsor pre-approves all audit and allowed
non-audit services of the Trusts independent registered public accounting firm, including all engagement fees and
terms.
48
PART
IV
****
Item
15. Exhibits, Financial Statement Schedules.
(a)(1) Financial Statements
For
a list of the financial statements included herein, see Index to the Financial Statements on page 30 of this Annual Report on Form 10-K,
incorporated into this Item by reference.
(b)(1)
Financial Statement Schedules
****
No
financial statement schedules are filed herewith because (i) such schedules are not required or (ii) the information required has been
presented in the aforementioned financial statements.
(c)(1)
Exhibits
****
The
following documents (unless otherwise indicated) are filed herewith and made a part of this Annual Report:
| 
Exhibit 
No. | 
| 
Exhibit Description | |
| 
3.1 | 
| 
First Amended and Restated Trust Agreement, incorporated by reference to Exhibit 3.1 of the Trusts Registration Statement on Form S-1 (File No. 333-282903), filed on October 10, 2025 | |
| 
3.2 | 
| 
Certificate of Trust, incorporated by reference to Exhibit 3.2 of the Trusts Registration Statement on Form S-1 (File No. 333-282903), filed on October 30, 2025 | |
| 
4.1 | 
| 
Description of Registrants Securities | |
| 
10.1 | 
| 
Form of Initial Authorized Participant Agreement, incorporated by reference to Exhibit 10.1 of the Trusts Registration Statement on Form S-1 (File No. 333-282903), filed on September 26, 2025 | |
| 
10.2 | 
| 
Marketing Agreement, incorporated by reference to Exhibit 10.2 of the Trusts Registration Statement on Form S-1 (File No. 333-282903), filed on September 26, 2025 | |
| 
10.3 | 
| 
Custodial Services Agreement, incorporated by reference to Exhibit 10.3 of the Trusts Registration Statement on Form S-1 (File No. 333-282903), filed on September 26, 2025 | |
| 
10.4 | 
| 
Administration Agreement, incorporated by reference to Exhibit 10.4 of the Trusts Registration Statement on Form S-1 (File No. 333-282903), filed on September 26, 2025 | |
| 
10.5 | 
| 
Transfer Agency Agreement, incorporated by reference to Exhibit 10.5 of the Trusts Registration Statement on Form S-1 (File No. 333-282903), filed on September 26, 2025 | |
| 
10.6 | 
| 
Fund Accounting and Servicing Agreement, incorporated by reference to Exhibit 10.6 of the Trusts Registration Statement on Form S-1 (File No. 333-282903), filed on September 26, 2025 | |
| 
10.7 | 
| 
Sponsor Agreement, incorporated by reference to Exhibit 10.7 of the Trusts Registration Statement on Form S-1 (File No. 333-282903), filed on October 10, 2025 | |
| 
10.8 | 
| 
Cash Custody Agreement (Custodian Agreement), incorporated by reference to Exhibit 3.1 of the Trusts Registration Statement on Form S-1 (File No. 333-282903), filed on September 26, 2025 | |
| 
10.9 | 
| 
Index Licensing Agreement, incorporated by reference to Exhibit 10.9 of the Trusts Registration Statement on Form S-1 (File No. 333-282903), filed on September 26, 2025 | |
| 
31.1 | 
| 
Certification by Principal Executive Officer of the Trust Pursuant to Rule 13a-14(a) under the Securities Exchange Act of 1934 | |
| 
31.2 | 
| 
Certification by Principal Financial Officer of the Trust Pursuant to Rule 13a-14(a) under the Securities Exchange Act of 1934 | |
| 
32.1 | 
| 
Certification by Principal Executive Officer of the Trust Pursuant to 18 U.S.C. Section 1350, As Adopted Pursuant to Section 906 of the Sarbanes-Oxley Act of 2002 | |
| 
32.2 | 
| 
Certification by Principal Financial Officer of the Trust Pursuant to 18 U.S.C. Section 1350, As Adopted Pursuant to Section 906 of the Sarbanes-Oxley Act of 2002 | |
| 
97.1 | 
| 
Recovery Policy for Erroneously Awarded Incentive-Based Compensation Policy | |
| 
101.INS | 
| 
Inline XBRL Instance Document the instance document does not appear in the Interactive Data File because its XBRL tags are embedded within the Inline XBRL document | |
| 
101.SCH | 
| 
Inline XBRL Taxonomy Extension Schema With Embedded Linkbase Documents | |
| 
104 | 
| 
Cover Page Interactive Data File included as Exhibit 101 (embedded within the Inline XBRL document) | |
49
SIGNATURES
****
Pursuant
to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, as amended, the Registrant has duly caused this Report
to be signed on its behalf by the undersigned*, thereunto duly authorized.
| 
| 
CANARY MARINADE SOLANA ETF | 
|
| 
| 
| 
| 
|
| 
Date: March
31, 2026 | 
By: | 
/s/ Steven McClurg | 
| 
|
| 
| 
Name: | 
Steven McClurg | 
|
| 
| 
Title: | 
Chief Executive
Officer (Principal Executive Officer)* | 
|
| 
| 
| 
| 
|
| 
| 
By: | 
/s/ Starr Frohlich | 
| 
|
| 
| 
Name: | 
Starr Frohlich | 
|
| 
| 
Title: | 
Principal Financial
and Accounting Officer | 
|
*
The Registrant is a trust and this person is signing in their capacity as an officer of Canary Capital Group LLC, the Sponsor of the
Registrant.
50