WisdomTree (WTGXX) Step Application

DAO Programs & Initiatives STEP Applications & Updates
1

Applicant information

Name: WisdomTree

Address (Headquarters): 250 West 34th St, 3rd Floor, New York, NY 10119

Country: USA

Website: https://www.wisdomtree.com/

Primary contact Name: Maredith Hannon

Title: Head of Business Development

Email, Telegram, Forum, & other methods of contact: mhannon@wisdomtree.com; (917) 267-3793

Key Information (as of March 17, 2025)*

SEC 30-Day Yield: 4.07%

Weighted Average Maturity: 7 days

Underlying asset: US Government Money Market Fund

Minimum/Maximum transaction size: $1

Current AUM for product: $112.5 million

Current AUM for WisdomTree affiliated issuer products worldwide: $113.9 billion

Volume of transactions LTM: $120.1 million

Source of first-loss capital: Not applicable to WTGXX as a US 1940 Act Fund

*Performance data shown represents past performance and is no guarantee of future results. Current performance may be higher or lower than that quoted. The Fund’s yield may be affected by changes in interest rates and changes in credit ratings. Income and/or dividends are not guaranteed. Performance data for the most recent month-end is available at wisdomtree.com/investments.

Basics and Background

  1. How will this investment improve Arbitrum’s RWA ecosystem?
  • An investment in WTGXX has the potential to directly enhance Arbitrum’s RWA ecosystem by providing a highly liquid, institutional-grade reserve asset, which may serve as a foundation for improved liquidity infrastructure while seeking to advance DeFi integrations with real-world assets. As a tokenized government money market fund backed by U.S. Treasuries, WTGXX can provide Arbitrum with a US regulated yield-generating solution, making it a highly competitive reserve asset for Arbitrum’s treasury as well as institutional participants within the ecosystem.
  • Beyond WTGXX, we offer a suite of tokenized funds designed to provide Arbritrum diversified exposure across multiple asset classes, including equities, fixed income, and a blend via asset allocation models, and gold (through a separate issuer). This range of products allows users to tailor their portfolios based on their risk appetite, investment objectives, and macroeconomic conditions. In an evolving market environment where liquidity, inflation concerns, and regulatory clarity continue to shape DeFi’s trajectory, our tokenized funds provide flexible, regulated, and institutionally managed options for capital allocation with a focus on compliance. By integrating these products into Arbitrum, ecosystem participants could access diversified, real-world financial instruments onchain, providing an alternative to crypto assets
  • As an institution with subsidiaries operating globally, WisdomTree brings extensive expertise in product development, structuring investment solutions, compliance, and risk management underlying our tokenized real-world assets which may serve to support Arbitrum’s evolving RWA investments. Our team is positioned to work directly with ecosystem participants on custom liquidity solutions, tailored investment strategies, and optimized reserve management frameworks. This collaboration could drive innovation in how RWAs are utilized within DeFi as Arbitrum seeks to remain at the forefront of institutional adoption.
  • Looking ahead, our DeFi roadmap focuses on expanding the utility of tokenized assets across key financial primitives, including lending markets, automated liquidity strategies, and cross-chain interoperability. WTGXX’s integration into Arbitrum could serve as a cornerstone for future liquidity enhancements, enabling seamless stablecoin conversions, collateral solutions, and onchain yield opportunities. By providing a scalable and regulated asset focused on compliance, WTGXX has the potential to facilitate deeper liquidity pools, improve capital efficiency in lending markets, and unlock new treasury management strategies for DAOs and institutional investors. Our long-term vision includes launching additional tokenized funds, enhancing instant settlement capabilities, and further developing infrastructure which, if launched and adopted, could serve to enable institutional-scale liquidity on Arbitrum.
  • Should WTGXX be selected as a reserve asset , it could serve as part of a foundation for a potentially more resilient, scalable, and accessible RWA ecosystem on Arbitrum. Our commitment to bridging institutional finance with DeFi seeks to provide products that we believe Arbitrum will find compelling in seeking to grow an ecosystem that remains at the forefront of the next evolution of tokenized real-world assets.
  1. Identify key management personnel and individual experience. Also include third parties utilized for managing assets and their qualifications.
  • WisdomTree, Inc. is a publicly held corporation (NYSE: WT) which operates via subsidiaries including those described herein. Select key team member biographies are listed below. Please see the public filings with the U.S. Securities and Exchange Commission (“SEC”) for each entity for applicable personnel information. Titles and biographies referenced below are generally descriptive of their corporate role and individuals may have different or no roles and titles for select WisdomTree subsidiaries.

    WisdomTree, Inc.
  • Jonathan Steinberg, Founder and Chief Executive Officer: Jonathan Steinberg founded WisdomTree and has served as Chief Executive Officer since October 1988 and as President from August 2012 to September 2019. He has been a member of the Board of Directors since October 1988, serving as Chair of the Board from October 1988 to November 2004. Mr. Steinberg is responsible for the creation and development of WisdomTree’s proprietary index methodology. He also served as Editor-in-Chief of Individual Investor and Ticker; two magazines formerly published by the Company. Prior to founding WisdomTree, Mr. Steinberg was employed as an analyst in the Mergers and Acquisitions Department of Bear, Stearns & Co. Inc., an investment banking firm, from 1986 to 1988. He is the author of Midas Investing, published by Times Books, a division of Random House, Inc., in 1996. Since May 2022, Mr. Steinberg has served on the Board of Directors of Fnality International Limited, a financial technology firm based in the United Kingdom. He received the EY Entrepreneur of the Year 2015 New York Award and the ETF.com Lifetime Achievement Award for 2015. Mr. Steinberg is a frequent speaker at conferences on topics related to digital assets and blockchain-enabled finance and has appeared on CNBC, Bloomberg and Fox Business on numerous occasions. He attended The Wharton School of Business at the University of Pennsylvania.
  • R. Jarrett Lilien, President and Chief Operating Officer: R. Jarrett Lilien has served as President and Chief Operating Officer since September 2019. From November 2017 to September 2019, he served as Executive Vice President and Head of Emerging Technologies. From November 2008 to December 2017, Mr. Lilien was a member of the Board of Directors and served on the Audit, Compensation and Nominating and Governance Committees. Until November 2017, Mr. Lilien was the Managing Partner of Bendigo Partners, LLC, a financial services focused venture capital investing and advisory services firm he founded in 2008. From September 2012 to July 2014, Mr. Lilien served as the Chief Executive Officer of Kapitall Inc., an online investing platform. From 2003 to 2008, he served as President and Chief Operating Officer of ETRADE Financial Corporation. In this role, he was responsible for the tactical execution of all of ETRADE’s global business strategies. Previously, he served as the President and Chief Brokerage Officer at ETRADE Securities. In this capacity, Mr. Lilien reorganized the business, adding new product lines and providing innovative brokerage capabilities to its retail, institutional and corporate clients around the world. With experience in more than 40 global markets, he was instrumental in developing a flexible infrastructure for ETRADE’s brokerage units designed to provide retail and institutional clients with seamless execution, clearing and settlement. Prior to joining ETRADE, Mr. Lilien spent 10 years as Chief Executive Officer at TIR (Holdings) Limited, a global institutional broker, which ETRADE acquired in 1999. Mr. Lilien currently serves as Chair of the Board of Directors of the Jazz Foundation of America, Chair of the Board of Directors of Barton Mines Corporation, and as Treasurer of Baryshnikov Arts. He served as a member of the Board of Directors of Investment Technology Group, Inc. (NYSE: ITG), an independent execution broker and research provider, from April 2015 until its acquisition by Virtu Financial, Inc. in March 2019, and served as interim Chief Executive Officer from August 2015 until January 2016. Mr. Lilien received his B.A. in Economics from the University of Vermont.
  • David Yates, Chief Information Officer: David Yates has served as Chief Information Officer since April 2015. He is responsible for WisdomTree’s global technology infrastructure, cybersecurity, information management and software engineering. He previously worked at McKinsey & Company from October 2009 to March 2015, most recently as an Associate Principal, advising investment management and insurance clients on a range of strategic technology and operations issues. He pioneered McKinsey’s advanced analytics approach for the insurance industry, laying the foundation for new engagement models and product offerings. He also co-led McKinsey’s IT Sourcing Practice in the Americas, where he was responsible for sharing expertise with clients during sales and procurement situations, creating industry-shaping content on sourcing, and training expert practitioners within the firm. From March 2005 to July 2007, he worked at Accenture plc, where he led multinational technology delivery programs in the capital markets space, including the design and implementation of the London Stock Exchange’s equity trading platform. Prior to that, he held technology roles at the Bank of England. Mr. Yates received his B.S. in Mathematics and Economics with First Class Honours from the London School of Economics and Political Science, an M.S. in Computing Science with Distinction from Imperial College London and an M.B.A. from MIT Sloan School of Management.

    WisdomTree Digital Assets
  • Will Peck, Head of Digital Assets: Will Peck has served as Head of Digital Assets since October 2021. In this role, he oversees digital asset initiatives. From February 2020 to October 2021, he served as Head of Strategy and Emerging Technologies, where he was responsible for oversight of corporate development and other strategic initiatives, including investments in emerging technologies. From September 2014 to January 2020, he held various positions within WisdomTree’s Strategy team, including Senior Analyst, Senior Associate and Director. From July 2012 to July 2014, he worked as an Investment Banking Analyst for Bank of America Merrill Lynch covering a range of financial services companies. He received an A.B. in Government, cum laude, from Harvard University.
  • Maredith Hannon, Head of Business Development, Digital Assets: Maredith Hannon joined WisdomTree in May 2022 and is the Head of Business Development for Digital Assets. In this role, she is responsible for leading business development and partnerships for WisdomTree’s digital assets division, including WisdomTree Prime and WisdomTree Connect. Prior to joining WisdomTree, she was an Executive Director at Morgan Stanley, Head of Business Development and Strategy for the Outsourced Chief Investment Office (OCIO) and previously held sales and strategy roles at Bank of America Merrill Lynch. She received an A.B., cum laude, from Georgetown University. She serves as Vice President of WisdomTree Securities and is Series 7, 65 and 24 registered.
  • Jason Guthrie, Head of Product, Digital Assets: Jason Guthrie is Head of Product for Digital Assets. Mr. Guthrie oversees the build out of the product offering for WisdomTree’s tokenization platform including smart contract development, tokenized exposures, WisdomTree Prime D2C application and WisdomTree Connect institutional offering. Additionally, he serves as a subject matter expert to the wider firm on the digital asset and crypto market and is involved in the strategy and development of indices and products related to this asset class. He started at WisdomTree in 2016 as Head of Capital Markets for the European ETF business. In 2019, he took on the additional role of Head of Digital Assets for WisdomTree Europe after his pivotal role in the construction and launch of the firms crypto ETP range. In 2021 he transitioned to his current role as a founding member of the digital assets division. Prior to joining WisdomTree, he worked at Deutsche Bank’s ETF Capital Markets group as well as Macquarie Bank as an Investment Executive based in Sydney, Australia. He holds a Bachelor of Commerce in Finance from Macquarie University in Sydney.
  • Ryan Louvar, Chief Legal Officer and Head of Business and Legal Affairs, Digital Assets: Ryan Louvar has over 25 years of legal experience with specific focus on ETFs, innovative products and digital assets and has served in his current role since 2021. Mr. Louvar was previously General Counsel of WisdomTree Asset Management, Inc. from 2013 until 2021, Vice President and Senior Managing Counsel at State Street from 2005 until 2013, where he served as the Chief Legal Officer, Secretary, Anti-Money Laundering (AML) Officer and Code of Ethics Compliance Officer for the SPDR family of ETFs. Mr. Louvar serves on various Investment Company Institute Committees, including the SEC Rules Committee, and is also involved in the Digital Chamber of Commerce, including as part of the Token Alliance Leadership Committee. Mr. Louvar received an LL.M. in Banking and Financial Law from Boston University, a J.D. degree from Pepperdine University School of Law and a B.S. in Finance, cum laude, from the University of Colorado.
  • Benjamin C. Dean, Director of Digital Assets Strategy: Benjamin C. Dean is Director for Strategy for Digital Assets. He focuses on overall digital asset strategy, research and external relations. Prior to joining the company, he was Cyber Catastrophe Lead at Hiscox Insurance Group. His work experience covers the opportunities and risks presented by emerging technologies for organizations including the OECD and the European Parliament. He was a Fellow for Cybersecurity and received a Master of International Affairs from the School of International and Public Affairs at Columbia University. He also graduated with honors from the University of Sydney with a Bachelor of Economic and Social Sciences.

    WisdomTree Digital Management, Inc./Asset Management Support
  • Jeremy Schwartz, CFA, Global Chief Investment Officer; Global Head of Research: Jeremy Schwartz has served as Global Chief Investment Officer of WisdomTree since November 2021 for WisdomTree and in relation to WisdomTree Digital Management since inception and leads WisdomTree’s investment strategy team in the construction of WisdomTree’s equity indexes, quantitative active strategies and multi-asset model portfolios. Mr. Schwartz joined WisdomTree in May 2005 as a Senior Analyst, adding to his responsibilities in February 2007 as Deputy Director of Research and thereafter, from October 2008 to October 2018, as Director of Research and from November 2018 to November 2021 as Global Head of Research. Prior to joining WisdomTree, he was head research assistant for Professor Jeremy Siegel and helped with the research and writing of Stocks for the Long Run and The Future for Investors. Mr. Schwartz also is co-author of the Financial Analysts Journal paper, “What Happened to the Original Stocks in the S&P 500?” He received his B.S. in Economics from The Wharton School of the University of Pennsylvania and hosts the Wharton Business Radio program Behind the Markets on SiriusXM 132. Mr. Schwartz is also a member of the CFA Society of Philadelphia.
  • Rick Harper, Chief Investment Officer of Fixed Income: Rick Harper oversees the suite of fixed income and currency exchange-traded funds and digital funds, as well as its model portfolio initiative, as applicable for WisdomTree’s asset management subsidiaries. He is a voting member of the WisdomTree Model Portfolio Investment Committee and takes a leading role in the management and oversight of the model allocations. He has helped develop many of the risk management oversight procedures at the firm.
    Mr. Harper has 30 years of investment experience in strategy and portfolio management positions at prominent investment firms. Prior to joining WisdomTree in 2007, he held senior level strategist roles with RBC Dain Rauscher, Bank One Capital Markets, ETF Advisors, and Nuveen Investments. At ETF Advisors, he was the portfolio manager and developer of some of the first fixed income exchange-traded funds. His research has been featured in leading periodicals including the Journal of Portfolio Management and the Journal of Indexes. He graduated from Emory University and earned his MBA at Indiana University.
  • Stuart Bell, Chief Operating Officer: Stuart Bell has served in this position since September 2019 for WisdomTree and in relation to WisdomTree Digital Management since inception. Previously, he served as WisdomTree’s Director of International Business; in this capacity he worked across all facets of our businesses in Europe, Japan and Canada where he helped drive operational alignment and execution of the Company’s strategic growth objectives. Earlier, Mr. Bell served as Director of Corporate Communications and Investor Relations from January 2012 to October 2016. He joined WisdomTree in September 2007 to run Public Relations and Corporate Communications adding responsibility for Investor Relations in conjunction with the Company’s 2011 listing on NASDAQ. Before joining WisdomTree, Mr. Bell worked at Sloane & Company, a strategic communications and investor relations firm. Mr. Bell received his B.A. in History, with departmental honors and honors in general scholarship, from Trinity College where he was Phi Beta Kappa and named the President’s Fellow in History.

    WTGXX (a series of WisdomTree Digital Trust)
    Information regarding the officers, directors and portfolio management team with respect to WTGXX (among other information) can be found in the Prospectus and Statement of Additional Information (“SAI”) at: https://www.wisdomtree.com/investments/resource-library/prospectus-regulatory-reports.
  1. Describe any previous work by the entity or its officers/key contributors similar to that requested. References are encouraged.
  • We have actively engaged with Arbitrum, affiliated stakeholders, and other related entities in efforts to fully understand the unique needs and objectives of the onchain community. In considering the ecosystem’s unique needs, WisdomTree’s investment solutions are able to: (1) unlock access to tokenized real-world-assets, (2) facilitate stablecoin conversion (e.g., from stablecoins to USD) to serve as a form of payment, (3) facilitate non-custodial wallet transactions and (4) implement onchain identity attestation via soulbound NFTs.
  • Leveraging our traditional finance and blockchain experience, we have developed products and platforms that seek to seamlessly integrate between the TradFi and DeFi worlds while implementing WisdomTree’s robust and rigorous compliance framework. We are committed to delivering best-in-class service for our clients, including adapting, building, and evolving our products, solutions, platforms, and integration points. As the industry evolves, WisdomTree will continue to develop bespoke solutions to provide regulated financial products, which could potentially include solutions built to the specific needs of Arbitrum and its affiliates.
  1. Has your entity or its officers/key contributors been subject to an enforcement action, criminal action, or defaulted on legal or financial obligations? Please describe the circumstances if so.
  • The issuing entity of WTGXX and its officers (key contributors) to the best of the issuing entity’s knowledge,have not been subject to any enforcement action, criminal action, or defaulted on legal or financial obligations.
  1. Describe any conflicts of interest for your entity and key personnel.
  • Please see WTGXX’s prospectus and statement of additional information for a discussion of various conflicts of interest and related mitigation, as applicable.
  1. Insurance coverages, guarantees, and backstops Name of insurer or guarantor Per incident coverage Aggregate coverage
  • WisdomTree maintains insurance coverages, and we will email the full details to Arbitrum.

  1. Historical tracking error in your proposed product, or similar to that being proposed Product 2024 2023 2022 2021
    – WTGXX was incepted on November 7, 2023 as a money market fund which is actively managed, and therefore does not track an index.

  2. Brief reason for above tracking error.

  • Not applicable per the above response to question 7.
  1. Please describe any experience your firm has in working with decentralized organizational structures
  • To gain a deep understanding of the Arbitrum community’s unique needs and objectives, we have engaged directly with decentralized organizational structures, advisory companies, and other protocols in Defi. This includes a robust suite of tokenized RWAs, two blockchain platforms to support both retail and institutional investors to access these assets, as well as developing new functionality to drive more utility for these assets, including stablecoin conversions, identity solutions, and instant redeemability.
  • In addition to the solutions and products detailed in this proposal, WisdomTree, through applicable global subsidiaries, has the ability to deliver customized asset allocation guidance and direct access to our research and expertise to meet Arbritrum’s specific investment objectives. Our Global Research Team and Chief Investment Office focus on four areas: product development, investment research, model portfolio management across various asset classes (equities, fixed income, alternatives, crypto), and strategic asset allocation. We can design and actively manage investment strategies that align with Arbitrum’s specific needs.
  • Arbitrum would gain access to WisdomTree’s senior advisors for insights and education. Our research is readily available through multiple platforms, allowing the Arbitrum community to stay updated with expert-driven content on current market trends and strategies. A copy of our Model Portfolio Investment Committee Q3 2024 Quarterly Strategic Outlook was emailed to rwa@dao.arbitrum.foundation.
  • We can also offer a comprehensive review of Arbitrum’s existing investments through personalized portfolio consultations, delivering forward-looking insights tailored to your objectives. Our team can analyze Arbitrum’s portfolio to potentially uncover hidden risks and provide actionable considerations to potentially enhance long-term performance.
  • Finally, we can provide Custom Model Portfolios, which are designed and managed specifically to meet Arbitrum’s objectives with a tailored approach to portfolio management, ensuring it is optimized for Arbitrum. Our extensive research, including white papers, market insights, and long-term strategies, will keep the community informed and empowered to make confident financial decisions.
  1. What is your entity’s current assets under management, assets held in trust, total value locked, or equivalent metric for your legal structuring?
    Below as of March 17, 2025:
  • WisdomTree and global subsidiaries worldwide: $113.9 billion
  • WTGXX: $112.5 million
  1. How many of these assets held are present on Arbitrum One, if any?

Plan design

  1. Please describe your proposed product, including a description of the underlying assets and, if more than one asset, the proposed allocation among assets and general investment guidelines. Where appropriate, include targeted maturity mix and credit quality. Attach supplementary documents as appropriate.
  • The WisdomTree Government Money Market Digital Fund (“WTGXX” or the “Fund”) seeks to provide investors with a high level of current income consistent with preservation of capital and liquidity and the maintenance of a stable $1.00 net asset value (“NAV”) per share. The Fund invests at least 99.5% of its total assets in government securities, cash and repurchase agreements collateralized fully by government securities or cash.
  • WTGXX is made available to institutions via our institutional platform, WisdomTree Connect™. WisdomTree Connect is a comprehensive solution for both business-to-business (“B2B”) and business-to-business-to-consumer (“B2B2C”) interactions. WisdomTree Connect enables clients to interact with WisdomTree-issued tokens, in any eligible self-hosted wallet or third-party custodial wallet service, across supported blockchains via a web portal and API. The WTGXX token available via WisdomTree Connect is an ERC-20 compatible token on Ethereum and in the near future, Arbitrum. WisdomTree facilitates orders and dividend payments in WisdomTree Connect via fiat (USD) and USDC (via the Stablecoin Conversion Service*).

    **Please note investors cannot directly purchase shares of the Fund via USDC but are processed via the Stablecoin Conversion Service that is an operational process facilitated by WisdomTree. All future references to the Stablecoin Conversion Service and operations are describing the client’s experience.
  • WTGXX invests in a portfolio of U.S. Treasury and government securities. Such securities may include: U.S. Treasury Notes (both fixed and floating rate), U.S. T-Bills, U.S. Government Agency Notes, including Discount Notes, that are either fixed or floating rate and issued by government agencies such as the Federal Home Loan Bank System, Federal Home Loan Mortgage Corporation (“Freddie Mac”), Federal National Mortgage Association (“Fannie Mae”) or the Federal Farm Credit Bank. The Fund may invest in repurchase agreements collateralized fully by U.S. Treasury securities, U.S. Government Agency securities or cash. The Fund may also invest in other investment companies that are government money market funds to the extent permitted under the Investment Company Act of 1940, as amended (the “1940 Act”).
  • The Fund has adopted a non-fundamental investment policy in accordance with Rule 35d-1 under the 1940 Act to invest under normal circumstances, at least 80% of the value of its net assets, plus the amount of any borrowings for investment purposes, in government securities and repurchase agreements that are collateralized by government securities.
  • The securities purchased by the Fund are subject to the quality, diversification, and other requirements of Rule 2a-7 under the1940 Act, and other rules adopted by the Securities and Exchange Commission (the “SEC”).
  • Please see the Prospectus and SAI for additional information, including additional strategy information and risk factors.
  • The Fund’s weighted average life is 42 days and weighted average maturity is 7 days with a 7-Day yield of 4.07% as of 3/17/25. Please see definitions and disclosures below the link to holdings details. *
  • Holdings details can be found here: https://www.wisdomtree.com/investments/digital-funds/money-market/wtgxx#money_market_holdings

    *Performance data shown represents past performance and is no guarantee of future results. Current performance may be higher or lower than that quoted. The Fund’s yield may be affected by changes in interest rates and changes in credit ratings. Income and/or dividends are not guaranteed. Performance data for the most recent month-end is available at wisdomtree.com/investments.
    7-Day Yield – The current yield reflects the current earnings of the Fund, while the total return refers to a specific past holding period. The 7-Day Yield is the average income return over the previous seven days, assuming the rate stays the same for one year. It is the Fund’s total income net of expenses, divided by the total number of outstanding shares and includes any applicable waiver or reimbursement. Absent such waivers or reimbursements, the returns would have been lower.
    Weighted Average Life (WAL) – For money market funds, this is the weighted average of the life of the securities held in a fund or portfolio and can be used as a measure of sensitivity to changes in liquidity and/or credit risk. Generally, the higher the value, the greater the sensitivity. WAL is based on the dollar-weighted average length of time until principal payments must be paid, taking into account any call options exercised by the issuer and any permissible maturity shortening features other than interest rate resets. For money market funds, the difference between WAM and WAL is that WAM takes into account interest rate resets and WAL does not.
    Weighted average maturity (WAM) – The weighted average maturity of the portfolio represents the market-weighted average of the maturities of the portfolio’s individual holdings. A money market fund in the United States must maintain a weighted average maturity of 60 days or fewer.
    Visit sec.gov to obtain the most recent 12 months of publicly available information filed by the Fund with the SEC on Form N-MFP.
  1. Do investors have any shareholder, investor, creditor or similar rights?
  • WTGXX is a registered 1940 Act Fund that enables shareholders to manage balances onchain while receiving the investor protections and benefits of shareholder rights under applicable U.S. law, including the 1940 Act. Shares of the Fund have a pro rata interest in its assets. Shares have no preemptive, exchange, subscription or conversion rights. Each share is entitled to participate equally in dividends and distributions declared by the Fund Board with respect to the Fund, and in the net distributable assets of the Fund on liquidation.
  • Each share has one vote with respect to matters upon which a shareholder vote is required consistent with the requirements of the 1940 Act and the rules promulgated thereunder. These shareholder voting rights generally include election of, or changes in, the Fund Board under applicable circumstances and approval of advisory agreements, including increases in management fees, each as further described in and subject to the Fund’s governing documents, Prospectus or otherwise as prescribed in the 1940 Act, as applicable.
  • The Ethereum token is a record of the investor’s Fund ownership. Under WisdomTree’s integrated recordkeeping system, the onchain record is aligned with book-entry records maintained by WisdomTree Transfers. WisdomTree Transfers maintains a master shareholder file for all primary market purchases, primary market sales, and peer-to-peer transfers of the token between eligible tokenholders.
  1. Describe the legal and contractual structuring for your product including regulatory bodies overseeing your business and the product and identifying all legal jurisdictions interacting with your product. Attach supplementary documents as appropriate.
  • In addition to the below, please reference the Fund’s Prospectus and SAI.
  • The Fund is an open-ended government money market fund registered under the 1940 Act in the U.S.The Fund is a series of the WisdomTree Digital Trust (the “Trust”). The Trust was organized as a Delaware statutory trust on April 19, 2021, and has multiple series or portfolios. The Trust is an open-end management investment company, registered under the 1940 Act. The Fund is “diversified” within the meaning of the 1940 Act. The offering of the Trust’s shares is registered under the Securities Act of 1933, as amended. The securities purchased by the Fund are subject to the quality, diversification, and other requirements of Rule 2a-7 under 1940 Act, and other rules adopted by the SEC.
  • WisdomTree Digital Management, as the investment adviser, has overall responsibility for the general management and administration of the WisdomTree Digital Trust and the Fund. WisdomTree, Inc. is the ultimate parent company of the Adviser.
  • WTGXX is registered with the SEC. WTGXX is issued by WisdomTree Digital Trust and managed by WisdomTree Digital Management, Inc. an SEC-registered investment adviser. The purchase and sale of Fund shares made through WisdomTree Connect is facilitated by WisdomTree Securities, Inc. (“WTS”), a broker-dealer registered with the SEC, Member FINRA. WTS does not receive or hold client funds or securities and is not a member of the Securities Investor Protection Corporation (“SIPC”). WisdomTree Transfers, Inc. is an SEC-registered transfer agent and serves as the transfer agent of the Funds.
  • Each WisdomTree Digital entity will provide the applicable institution with the relevant services.
  1. Would Arbitrum’s assets be bankruptcy remote from your own entity and its officers/key contributors? If so, please explain the legal and contractual basis. On a confidential, non-reliance basis, provide any third party legal opinions to support the conclusions.
  • Yes. The WisdomTree Digital Trust structure in place is to limit bankruptcy risks and protect shareholders under the 1940 Act. The Trust’s assets are held with an independent custodian, Bank of New York, in a segregated account. In the case of a bankruptcy of WisdomTree or any of its providers, including the custodian, WisdomTree, Inc. and its affiliates would have no claim to the Trust’s assets and the Trust would not be part of the bankruptcy proceedings.
  1. How are Arbitrum’s assets protected vis-a-vis the bankruptcy of the brokerage or applicable financial institution (e.g., bank deposit insurance, securities insurance, etc.)?
  • As stated above, Arbitrum’s assets would be protected from bankruptcy risks through the fund structure governed by the 40 Act. This structure provides multiple layers of investor protection. One of the key protections is independent oversight. The WTGXX fund operates as a series of the WisdomTree Digital Trust, which is overseen by a board of trustees. This board consists of four individuals, three of whom are independent, ensuring that they are not employees of WisdomTree. Their independence is governed by specific requirements under the 1940 Act. The biographies of these trustees are disclosed in the Fund’s Statement of Additional Information (SAI). The board holds the authority to approve all material contracts for the Trust, including the appointment of WisdomTree Digital Management as the Adviser. If the board determines that it is in the best interest of fund shareholders, it has the power to terminate WisdomTree Digital Management and appoint a different adviser. Additionally, shareholders have recourse through calling and holding meetings, where they can vote to remove trustees or take other actions as permitted.
  • The fund structure also provides bankruptcy remoteness. The assets of WTGXX are held with an independent custodian in a segregated account, ensuring that they are not comingled with WisdomTree’s assets. This setup means that in the event of a bankruptcy affecting WisdomTree or any of its service providers, including custodians, the assets of the Fund would not be part of the bankruptcy estate. This helps ensure that the Fund’s holdings remain intact and separate from any potential financial distress or insolvency issues affecting WisdomTree or other related entities​.
  1. Does the Issuer issue more than one asset? If so, what is the priority relationship between different asset classes?
  • Yes, and there is no priority relationship between the different asset classes based on the trust structure that is overseen by an independent board of trustees. In addition to WTGXX, we have developed a full suite that includes 12 other tokenized funds covering equity, fixed income, and asset allocation models, in addition to tokenized gold and a stablecoin (issued by a separate issuer). By onboarding to our platform and subject to applicable onboarding requirements, Arbitrum can potentially access current and future products as they become available and as we continue to innovate, which we believe could be the types of products and services of benefit to Arbitrum. Our products provide increased optionality to Arbitrum’s treasury management through enhanced diversification as well as additional yield opportunities. Together, these funds seek to provide investors with access and selection to the asset class, structure, and accessibility required by their own unique situation while being assured of a regulated, established asset manager issuing and managing the Funds. Our full suite of digital funds may be found here: https://www.wisdomtree.com/investments/digital-funds.
  1. Provide a detailed cash flow diagram that shows the flow of funds from ARB/Fiat conversion, investment in underlying asset, payment of expenses, sale of underlying asset, and repayment (Fiat/ARB conversion), including the counterparties and legal jurisdictions involved.
  • The full process is described below assuming transacting through USDC:
  • Subscription:
    a. Arbitrum (client) submits purchase order for desired amount (cutoff is 12:00 pm ET)1
    b. Arbitrum sends USDC to blockchain address provided by WisdomTree (cutoff is 1:00 pm ET)
    c. WisdomTree confirms receipt of USDC
    d. Stablecoin conversion:
    – WisdomTree sends USDC to WisdomTree’s Circle account
    – WisdomTree Circle account burns USDC and WisdomTree sends USD to the Fund custody account
    e. Order fulfillment:
    – Order fulfilled following 4:00 pm ET NAV calculation
    – WisdomTree Transfers records shareholder ownership
    – WisdomTree mints WTGXX tokens and sends tokens to the client’s wallet address.
    1 WisdomTree does not charge brokerage commissions for WTGXX orders. Management fees still apply.

  • Redemption:
    a. Arbitrum (client) submits redemption order for desired amount (cutoff is 12:00 pm ET)1
    b. Arbitrum sends WTGXX tokens to specified WisdomTree wallet (cutoff is 1:00 pm ET)
    c. WisdomTree confirms receipt of WTGXX tokens
    d. Order fulfillment
    – WisdomTree burns WTGXX tokens
    – Order fulfilled following 4:00 pm ET NAV calculation
    – WisdomTree Transfers updates records of shareholder ownership
    e. Stablecoin conversion:
    – WisdomTree sends redemption value amount in USD to WisdomTree Circle Account
    – WisdomTree Circle Account mints USDC and sends to client’s wallet address directly
    1WisdomTree does not charge brokerage commissions for WTGXX orders. Management fees still apply.

WTGXX Transaction Flow_FINAL
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  1. Describe anticipated tax consequences (if any) in transacting on the underlying and/or receipt of yield.
  • In the case of WTGXX, income distributions generally are characterized as “interest-related dividends,” which are generally exempt from U.S. withholding taxes, provided certain other requirements are met.
  • Please refer to WTGXX’s Prospectus and SAI for a more detailed explanation of the tax consequences of investing in the Fund.
  • Neither WisdomTree, Inc., nor its affiliates provide tax advice. All references to tax matters or information provided should not be considered tax advice and cannot be used for the purpose of avoiding tax penalties. Investors seeking tax advice should consult an independent tax advisor.
  1. Describe the process and expected timeline for liquidation of assets, if given instructions to do so by Arbitrum governance.
  • The generally expected time frame for the settlement of subscriptions and redemptions on U.S. trading days is T+0 (same day). Orders and payments must be received by the applicable cut-off time on U.S. trading days (12:00 PM ET for orders and 1:00 PM ET for payments) to receive WTGXX shares the same day. Subscriptions and redemptions generally settle shortly after the NAV strike at 4:00 pm ET. The Transfer Agent records all subscriptions and redemptions for the Fund. To date, the Transfer Agent has not had any interruptions in the ability to process transactions in the SEC prescribed timeframes.
  1. What amount of first-loss equity will Sponsor provide to ensure over-collateralization, how is the first-loss equity denominated, and what is the source of capital?
  • This question is not applicable with respect to WTGXX, a product structured under the 1940 Act with its related requirements associated with maintenance of a $1.00 net asset value, including requirements for segregated custody, underlying asset quality, valuation, liquidity and maturity.
  1. Describe the liquidity and stability of the proposed underlying assets, including anticipated settlement times from the sale of the underlying to the repayment of ARB.
  • WTGXX invests in a portfolio of U.S. Treasury and government securities.
    The securities purchased by the Fund are subject to the quality, diversification, and other requirements of Rule 2a-7 under the 1940 Act, and other rules adopted by the SEC. The Fund maintains a policy pursuant to Rule 2a-7 to which the Adviser and the Sub-Adviser must follow. Rule 2a-7 is the principal rule governing money market funds in the U.S. This rule covers a range of topics that seek to ensure the ability of WTGXX to maintain a stable $1.00 NAV and meet redemption orders in a timely manner. These topics include maturity of investments, type and quality of investments, issuer diversification, disclosure of portfolio holdings, fund liquidity, determination of amortized cost-based and market-based NAVs, and stress testing. Stress testing includes periodically testing and reporting to the WisdomTree Digital Trust Board of Trustees, which oversees the Fund (“Fund Board”), the test results, assumptions, and related assessments of the Fund’s ability to withstand stressful economic and financial market conditions. Further, with respect to portfolio liquidity, WTGXX must hold securities that are sufficiently liquid to meet reasonably foreseeable shareholder redemptions in light of the Fund’s obligations under section 22(e) of the 1940 Act to timely process shareholder redemptions. Specifically, this means WTGXX must maintain 25% of total assets in Daily Liquid Assets, 50% of the total assets in Weekly Liquid Assets, and a 5% maximum limit for investment in “illiquid” securities at the time of acquisition (defined as any security that cannot be sold or disposed of within seven days at approximately the market value ascribed to it).
  1. If relying on the blockchain for any of the transactional flows, please describe any blockchain derived risks and mitigations.
  • WisdomTree’s WTGXX fund leverages blockchain technology with a focus on security, efficiency, and transparency, but like any digital system, it carries certain risks. Potential challenges include cybersecurity threats, smart contract vulnerabilities, regulatory changes, transaction delays, and private key security concerns, among others as more fully described in the Prospectus and SAI. In seeking to mitigate these, WTGXX integrates institutional-grade encryption and compliance controls, uses multi-layer security authentication, and maintains off-chain reconciliation for accurate record-keeping. Additionally, the fund is supported by security audits, regulatory oversight, and blockchain-integrated recordkeeping in seeking to maintain a secure and compliant blockchain-based investment solution. Please refer to the Prospectus and SAI for more details on Blockchain risks.
  1. Does the product rely on any derivative product (swaps,OTC agreements?
  • WTGXX does not rely on any derivative products.
  1. List all the third party counterparties linked to your assets including and not restricted to prime broker if any, custodian, reporting agent, banks for derivatives or loans and provide primary contact details for the third party counterparties
  • WisdomTree utilizes a third-party unaffiliated Sub-Adviser, Custodian and Administrator (as noted under question 4 above) to perform trading, portfolio management, custody, and administrative activities, as applicable, each of which are large, publicly traded, and experienced providers. WisdomTree conducts due diligence for all potential service provider relationships, along with ongoing oversight of existing providers. The process involves a detailed review of processes, contracts, on-site/virtual visits and final approval by the Fund Board (of which 75% of the Fund Board members are independent of WisdomTree).
  • In addition, the Sub-Adviser has a fiduciary duty to manage WTGXX in a fair and equitable manner, and all third-party service providers must comply with all federal rules and regulations regarding trading, investment management, and administrative activities. For general information on WisdomTree’s third-party oversight, please see the Corporate Responsibility Report. Information specific to WTGXX can also be found in WTGXX’s SAI.
  • WTGXX and Its Service Providers:
    WisdomTree, Inc is the ultimate parent company of the WisdomTree named entities below:
    a. Investment Adviser: WisdomTree Digital Management, Inc. (“Adviser”)
    – The Adviser serves as the investment adviser to the Fund. The Adviser is a Delaware corporation registered with the SEC as an investment adviser under the Investment Advisers Act of 1940. The Adviser is responsible for the overall general management and administration of the Fund.
    – WisdomTree Digital Management provides an investment program for the Fund. The Adviser also provides proactive oversight of the Sub-Adviser, daily monitoring of the Sub-Adviser’s buying and selling of securities for the Fund, and regular review of the Sub-Adviser’s performance. In addition, the Adviser arranges for, and oversees, sub-advisory, transfer agency, custody, fund administration, securities lending, and all other non-distribution-related services necessary for the Fund to operate.

    b. Sub-Adviser: Voya Investment Management Co. LLC (“Voya IM”)
    – Voya IM is responsible for the day-to-day management of the Fund. Voya IM manages the Fund’s portfolio investments and places orders to buy and sell the Fund’s portfolio investments.
    – Voya IM, a registered investment adviser, is the asset management business of Voya Financial (NYSE: VOYA), overseeing approximately $336 billion in assets for institutions, financial intermediaries and individual investors. Voya IM is one of the 50 largest institutional asset managers globally. Drawing on a 50-year investing legacy and the expertise of 300+ investment professionals, Voya IM strategies span public and private fixed income, equities, multi-asset solutions and alternatives.

    c. Administrator and Custodian: Bank of New York (“BNY”)
    – BNY provides certain administrative, legal, tax, and financial reporting services for the maintenance and operations of the Fund as well as acts as custodian of the assets of the Fund. BNY is required, upon the order of the Fund, to deliver securities held by State Street and to make payments for securities purchased for the Fund.

    d. Transfer Agent: WisdomTree Transfers, Inc. (“Transfer Agent”)
    – WisdomTree Transfers acts as transfer agent for the authorized and issued shares of beneficial interest for the Fund and as dividend disbursing agent of the Trust. The Transfer Agent maintains the official record of share ownership in book-entry form. Under WisdomTree’s integrated recordkeeping system, the onchain record is aligned with book-entry records maintained by WisdomTree Transfers.

    e. Auditor: Ernst & Young LLP (“EY”)
    – EY is one of the world’s largest accounting firms, providing global tax, audit, and advisory services to thousands of clients. EY audits WTGXX’s financial statements annually in seeking to ensure accurate and compliant financial reporting.

    f. Distributor in the U.S.: Foreside Fund Services, LLC (the “Distributor”)
    – The Distributor has entered into a Distribution Agreement with the Trust pursuant to which it distributes shares of the Fund.

    – Other Key Entities:
    a. Broker-Dealer: WisdomTree Securities, Inc.
    – Facilitates the purchase and sale of Fund shares made through WisdomTree Connect (“Portal”) on an application way basis and is a broker-dealer registered with the SEC, Member Financial Industry Regulatory Authority (“FINRA”).

    b. Money Movement & USDC Stablecoin Conversion Service:

    c. WisdomTree Digital Movement, Inc. (“WDM”)
    – WDM makes available the Stablecoin Conversion Service which enables institutions to utilize USDC and have it converted to USD to fund their purchase orders that are entered through the WisdomTree Connect Portal. WDM is a federally registered money services business, state-license money transmitter and financial technology company (NMLS ID: 237500).

    d. Circle Internet Financial, LLC (“Circle”)
    – Circle executes mint and burn services of USDC transactions. Circle issues USDC, a digital token, and handles the redemption and issuance of USDC as part of the Stablecoin Conversion Service made available by WDM.

    e. Banking Services: Bank of New York (“BNY”)
    – Operates as a banking service provider for WDM.
  1. Can you explain how is risk management (inv and operational) being done? Can you provide a copy of your risk management policy?
  • Overall Corporate Risk Management: The Enterprise Risk Management (ERM) Framework within the subsidiaries of WisdomTree focused on digital assets and/or blockchain (“WisdomTree Digital”) provides a structured and proactive approach to identifying, assessing, and managing risks across its digital asset business, ensuring alignment with regulatory requirements and industry best practices. The framework integrates risk management into strategic decision-making, fostering a risk-aware culture and employing continuous monitoring, control testing, and governance oversight seeking to protect assets, ensuring operational resilience, and maintain regulatory compliance. Key components of the Risk Management framework include Risk and Control Self Assessment (RCSA), Blockchain Risk Assessments including real time monitoring of both the Chain and Asset (WTGXX) by leveraging the Metrika platform.
  • WTGXX Fund Specific Risk Management:
    a. Specifically with respect to WTGXX, risk management seeks to identify and eliminate or mitigate the potential effects of risks, i.e., events or circumstances that could have material adverse effects on the business, operations, shareholder services, investment performance or reputation of the Fund. Service providers to the Fund employ a variety of processes, procedures and controls to identify risks relevant to the operations of the Fund to lessen the probability of their occurrence and/or to mitigate the effects of such events or circumstances if they do occur. Each service provider is responsible for one or more discrete aspects of the Fund’s business (e.g., WisdomTree Digital Management, Inc. (Adviser) and, more particularly, WTGXX’s sub-adviser is responsible for the day-to-day management of the Fund’s portfolio investments) and, consequently, for managing the risks associated with that activity. The Fund’s prospectus includes a description of certain risks applicable to the Fund, some or all of which may adversely affect the Fund. However, certain aspects of risk mitigation are described below:
    – Credit risk: Credit risk is limited as government money market funds are generally limited to certain investments as described in the Prospectus, such as US Treasury securities, US government guaranteed securities, US government agency securities, repurchase agreements fully collateralized by those three security types and cash.
    – Interest rate risk: Interest rate risk is limited due to factors such as a the 60-day maximum weighted average maturity. The Fund WAM is positioned between 1-day and 60-days based on outlook for short-term interest rates and yields which are mainly driven by changes in FED policy and to some extend supply and demand for the limited universe of eligible securities.
    – Liquidity risk: The portfolio is managed in striving to maintain excess liquidity over and above the SEC required 25% minimum in daily liquidity and 50% minimum in weekly liquidity. Historical shareholder activity and any future anticipated shareholder can be taken into consideration when determining if excess liquidity is necessary.

Performance reporting

  1. What are your proposed performance benchmarks? If this is substantially different from the underlying assets, please explain why.
  • The Fund’s performance is benchmarked to the ICE US 1-Month Treasury Bill Index.
  1. Describe the content, format, preparation process, and cadence of performance reports. This should include proof of reserves, if appropriate. Please include a sample report.
  • WTGXX holdings and performance are available publicly at https://www.wisdomtree.com/investments/digital-funds/money-market/wtgxx. The Fund will disclose its portfolio holdings approximately five business days after the end of each month on the website above. When portfolio holdings are updated, changes are reflected on the first business day following month end.
    – WisdomTree Connect users generally receive monthly statements via email.
    – A sample copy will be emailed to Arbitrum.
  1. Who provides the performance reports in respect of the underlying assets?
  • Performance updates: WTGXX holdings and performance are available publicly on a monthly basis at https://www.wisdomtree.com/investments/digital-funds/money-market/wtgxx. The Fund will disclose its performance approximately seven business days after the end of each month on the website above. WisdomTree Connect users generally receive monthly statements via email.
  1. Describe any formal audit process and timing of such audits.
  • EY serves as the independent registered public accounting firm to the Trust that performs the annual audit.
  • The Audit Committee is comprised of three independent Fund Board members. The principal responsibilities of the Audit Committee are the appointment, compensation and oversight of the Trust’s independent registered public accounting firm, including the resolution of disagreements regarding financial reporting between Trust management and such independent registered public accounting firm, among other responsibilities. Annually, the independent registered public accounting firm reviews with the Audit Committee its audit of the Fund’s financial statements.
  • A smart contract audit has been conducted by Oxorio and OpenZeppelin. Audit reports for the smart contract performed by Oxorio are publicly available at Token Standards and Token Standard Annex. The audit report from OpenZeppelin is available at: WisdomTree Digital Whitelist Contexts Audit

Pricing

  1. Provide a copy of your standard contract, or one similar to what is being proposed here.
  • We will send a copy of our Terms and Conditions document to Arbitrum.
  1. Fee summary: Inclusive of the full scope of services requested. Product Fee schedule If asset based Fee calculation for our plan if asset based Annual fee if flat fee Any other fees (including redemption or minting fees)
  • The expense ratio is 0.25%. There are no transaction, subscription or minting fees or other service fees. Investors are responsible for gas fees for their transfers of tokens to another wallet, such as utilizing USDC via the Stablecoin Conversion Service and potentially stablecoin burn fees.
  • Fees and Expenses of the Fund
    The following table describes the fees and expenses you may pay if you buy, hold, and sell shares of the Fund. The fees are expressed as a percentage of the Fund’s average net assets.
Column 1 Column 2
Shareholder Fees (fees paid directly from your investment) None
Annual Fund Operating Expense (expenses that you pay each year as a percentage of the value of your investment)
----- Management Fees 0.25%
----- Distribution and / or Services (12b-1) Fees None%
----- Other Expenses 0.00% 1
Total Annual Fund Operating Expenses 0.25%

1 “Other Expenses” are based on estimated amounts for the current fiscal year.

  1. Describe frequency of fee payment and its position vis-a-vis payment priority compared with other expenses (i.e., cash waterfall)
  • Fees for WTGXX are accrued daily. Each day, a prorated portion of that annual fee is deducted from the fund’s net assets, ensuring the net asset value (NAV) reflects investors’ appropriate share net of fees.
  • All fees are described above and in the Fund’s Prospectus. Unlike many other types of investment vehicles and funds, which may charge investors a variety of “other” expenses, the Adviser provides investment advisory services and pays the Fund’s operating expenses in return for a “unitary fee”, and pays such other expenses, with certain limited exceptions.

Smart Contract/Architecture

  1. How many audits have you had and name of auditors? Please provide a copy of reports.
  • A smart contract audit has been conducted by Oxorio and OpenZeppelin. We have had two rounds of audit on the existing code base as of August 31, 2024. Any future adjustments or changes to the code base will be audited prior to deployment. The Oxorio audit reports for the smart contract are available at Token Standards and Token Standard Annex. The audit report from OpenZeppelin is available at: WisdomTree Digital Whitelist Contexts Audit
  1. Is the project permissioned? If so how are you managing user identities? Any blacklisting/whitelisting features?
  • Potential investors in WTGXX are required to complete traditional KYC (including enhanced due diligence, as applicable) and AML regulatory processes to participate as investors and wallet screening is conducted with respect to potential wallets onboarded via WisdomTree Connect. Once the investor completes the onboarding process, an onchain attestation, represented by a non-transferable soulbound NFT, is issued to the investor’s wallet and only those registered wallets can participate in transactions. WisdomTree issued soulbound NFTs cannot be transferred and can be revoked by WisdomTree in the event that client status or conditions change. Shareholders can also peer-to-peer transfer WTGXX tokens to other onboarded shareholders with registered wallets as described above with the Transfer Agent maintaining the official record of share ownership. In this manner, WisdomTree prevents transactions between unknown persons or unknown blockchain wallets.
  1. Is the product present on several chains? Are there any cross chain interactions?
  • WTGXX is currently able to be minted on Ethereum and Stellar; and will soon be deployed on Arbitrum, Avalanche, Base, and Optimism.
  • We will be deploying on select other chains over time. We consistently monitor the ecosystem evolving and continue to develop new, innovative ways to provide access to our solutions.
  • There are currently no cross-chain interactions, but we continue to explore product enhancements to enable more defi integrations.
  1. Are the RWA tokens being used in any other protocols? Please describe the various components of the ecosystem
  • We consistently monitor the ecosystem evolving and continue to develop new, innovative ways to provide access to our solutions where there is demand.
  • We are also focused on the development of secondary market functionality for our offerings with the goal of utilizing the full potential of blockchain technology across various protocols. Research & development efforts currently underway include integration of atomic swaps, contingent transactions, oracles, time locks, account abstraction, third party attestations for KYC / AML verification, and zero knowledge proofs. We are also leveraging our position and connectivity to the wider financial markets to deliver on our vision to bring more traditional financial services onchain, including market making, pricing, credit facilitation and advanced risk management.
  1. How are trusted roles/admins managed in the system? Which aspects of the solution require trust from users?
  • Our protocol extends upon the AccessControl library by OpenZeppelin to implement role-based access control. Each contract in the system inherits from this AccessControl and defines specific roles for its operations. WisdomTree runs a dual-location key management approach: one cold location for critical functions and an MPC solution for daily management/high throughput functions.
  • Please reference our smart contract audit with OpenZeppelin at: WisdomTree Digital Whitelist Contexts Audit
  1. Is there any custom logic required for your RWA token? If so please give any details.
  • No, all token standards are built upon an extended ERC-20 standard, which provides the basic functionality of an ERC-20 token including features like minting, burning, transfers, and allowances. This standard ensures that all tokens adhere to the ERC-20 standard, which is a widely adopted standard for fungible tokens on EVM blockchains. It serves as the foundation for more advanced token standards by seeking to ensure basic functionality and security in token transactions. Our most advanced standard integrates compliance checks directly into token operations, in seeking to ensure that every transaction automatically adheres to the relevant regulatory requirements.

Supplementary

  1. Please attach any further information or documents you feel would help the screening committee or ARB tokenholders make an informed decision. If you prefer this not to be made public, it can be emailed to rwa@dao.arbitrum.foundation. Please mention in your application that documents have been emailed for committee review.

IMPORTANT INFORMATION

Investors should carefully consider the investment objectives, risks, charges and expenses of the Fund before investing. To obtain a prospectus containing this and other important information, please call 866.909.9473, or visit /WisdomTree.com/investments to view or download a prospectus online. Read the prospectus carefully before you invest. There are risks involved with investing, including the possible loss of principal. Past performance does not guarantee future results.

You could lose money by investing in the Fund. Although the Fund seeks to preserve the value of your investment at $1.00 per share, it cannot guarantee it will do so. An investment in the Fund is not a bank account and is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. The Fund’s adviser is not required to reimburse the Fund for losses, and you should not expect that the adviser will provide financial support to the Fund at any time, including during periods of market stress.
PRODUCTS AND SERVICES AVAILABLE VIA WISDOMTREE CONNECT: NOT FDIC INSURED | NO BANK GUARANTEE | NOT A BANK DEPOSIT | MAY LOSE VALUE | NOT SIPC PROTECTED | NOT INSURED BY ANY GOVERNMENT AGENCY

WisdomTree Digital Funds are distributed by Foreside Fund Services, LLC. Foreside Fund Services, LLC is not affiliated with the other entities.

The products and services available through the WisdomTree Connect portal are not endorsed, indemnified or guaranteed by any regulatory agency.

The WisdomTree Connect portal and certain related services described herein are made available through WisdomTree Digital Movement, Inc., a federally registered money services business, state-licensed money transmitter and financial technology company (NMLS ID: 2372500).

WisdomTree Transfers, Inc., the Fund’s transfer agent, maintains the official record of share ownership through an integrated recordkeeping system with records in book-entry form and records that are recorded – or digitized – on the Ethereum blockchain. In order to facilitate the use of blockchain technology, a potential institutional shareholder must have a blockchain wallet. WisdomTree Securities, Inc., an affiliate of WisdomTree Transfers and WisdomTree Digital, facilitates the ability for Fund investors on an “application-way” basis to purchase or sell shares.

A blockchain is an open, distributed ledger that digitally records transactions in a verifiable and immutable (i.e., permanent) way using cryptography. A distributed ledger is a database in which data is stored in a decentralized manner. Cryptography is a method of storing and transmitting data in a particular form so that only those for whom it is intended can read and process it. A blockchain stores transaction data in “blocks” that are linked together to form a “chain”, and hence the name blockchain. Blockchain technology is a relatively new and untested technology, with little regulation. Blockchain systems could be vulnerable to fraud, particularly if a significant minority of participants colluded to defraud the rest. Potential risks also include vulnerability to theft, or inaccessibility, and future regulatory developments could affect its viability.

The information provided is for informational purposes only and intended solely for institutions. The information is a summary of steps and not a complete or comprehensive guide to all steps or actions related to shareholder onboarding, transactions, settlement and related matters.
The information is not intended to serve as a recommendation to buy, hold or sell any asset or to engage in any investment or trading strategy or to use any service. The information herein should not be relied on and is not a substitute for the skill, judgment and experience of the user when making investment and other business decisions. All information is impersonal and not tailored to the needs of any person, entity or group of persons. None of the information constitutes an offer to sell or a solicitation of an offer to buy, any security or other asset, financial product or other investment vehicle or any trading strategy, or service, and should not be viewed as trading or investment advice. Potential products and services, as well as applicable launch timing and associated fees, are in development, will require third party relationships and may change or may never become available, including due to regulatory considerations. Any information provided and/or plans associated herewith are subject to change without notice and WisdomTree is under no obligation to provide additional information.