Deposito S‑1 presentato alla SEC il 25 agosto 2025: Canary Capital mette sul tavolo l’ETF cripto USA “Canary American‑Made Crypto ETF.Deposito S‑1 presentato alla SEC il 25 agosto 2025: Canary Capital mette sul tavolo l’ETF cripto USA “Canary American‑Made Crypto ETF.

Crypto “Made in USA”: Canary Capital launches the ETF MRCA on Cboe BZX and focuses on star-spangled tokens (Bitcoin and Ether probably excluded)

6 min read

S-1 filing submitted to the SEC on August 25, 2025: Canary Capital puts the USA crypto ETFCanary American‑Made Crypto ETF” with ticker MRCA on the table, designed to offer exposure to digital assets with predominantly American roots and with a planned listing on Cboe BZX.

The fund aims to transparently replicate the proprietary index, operating through direct exposure – without leverage and without derivatives – and entrusting custody to a trust regulated in the United States. It should be noted that the setup is deliberately essential, with a straightforward operational architecture.

According to the data collected from the analysis of public filings and reports from market operators, the SEC’s requests for clarification on crypto products tend to focus on custody, governance, and risks related to staking.

Industry analysts observe that a geographical filter like the “Made‑in‑USA” requirement can facilitate regulatory dialogue on compliance aspects, while not eliminating the need for operational details (e.g., names of custodians and slashing policies).

In the past, similar processes have seen documentary integrations requested by the SEC within a timeframe that typically varies from 30 to 120 days.

What MRCA offers new

MRCA is created to channel capital towards protocols and tokens closely linked to the development, governance, or infrastructure of the United States. The proposal includes:

  • Physical replication of the index through the direct purchase of eligible tokens;
  • Exclusion of stablecoin, memecoin, and tokens pegged to traditional currencies or assets;
  • Quarterly rebalancing of the index, with criteria related to liquidity and compliance;
  • Possibility of staking for proof‑of‑stake consensus assets through third-party providers, with rewards reinvested in the NAV;
  • Custody entrusted to a regulated trust (based, for example, in South Dakota) and management of the majority of reserves in cold storage (custody insight).

“Made‑in‑America Blockchain Index”: selection criteria and exclusions

The “Made in America” index includes exclusively cryptocurrencies created, mined, or predominantly managed in the United States and traded on established platforms.

Admission is evaluated by an independent oversight committee and requires compliance with specific minimum market requirements. An interesting aspect is the focus on traceability of origin and governance.

Requirements for inclusion

  • Custody: it is necessary that the token be custodial with a trust or a regulated custody bank in the USA.
  • Liquidity and depth: assets must have adequate liquidity and be listed on multiple recognized exchange;
  • Due diligence and approval by an independent committee, with continuous monitoring of technical and legal risks;
  • Exclusions: stablecoin, memecoin, and tokens pegged to traditional currencies or assets.

Rebalancing and weights

The basket adopts a quarterly rebalancing (every 90 days) to update both the composition and the weights of the assets based on liquidity, capitalization, and compliance, introducing anti-concentration limits useful for mitigating idiosyncratic risk. In this context, the management of the weights appears pragmatic.

Custody and staking: the fund’s operations

The digital assets will be held by a regulated trust in the United States, with strict controls to ensure segregation and security of reserves, primarily in cold storage.

For assets with a proof‑of‑stake mechanism, the trust may delegate staking to third-party providers, reinvesting any rewards into the fund’s assets and applying safeguards on slashing, lock-up periods, and operational risks. It should be noted that the prospectus clarifies how the fund will operate without financial leverage or derivatives.

Potential candidates and the “USA origin” criterion

Among the projects that could meet the criteria – subject to verification of the presence of custody infrastructures and adequate liquidity – are indicatively included Solana (SOL), Ripple/XRP, Chainlink (LINK), Stellar (XLM), and, in some cases, Algorand (ALGO).

The “Made in USA” requirement refers to projects where development, governance, or infrastructure have a strong American footprint, even if in some cases the origin may be partial or subject to debate. 

In this context, the geographical filter might exclude assets like Bitcoin and Ether, considered expressions of a global ecosystem and not uniquely attributable to the United States.

Regulatory process: status of the request and next steps

Canary Capital has filed the Form S‑1 with the SEC, aiming to obtain approval for listing on Cboe BZX (ticker MRCA). The standard process requires the SEC to declare the prospectus “effective,” and for an ETF with underlying cryptocurrencies, approval of a listing procedure via Form 19b‑4 by the exchange might also be necessary. 

The publication of the prospectus and the SEC effectiveness declaration can require varying times (from days to over 120 days, depending on the requests for integration).

For the listing process, the rules and requirements of Cboe for listing and 19b‑4 also apply, which require additional documentation from the exchange.

The timing remains sensitive: after the approval of the first spot ETFs in recent years, the SEC continues to carefully evaluate products that involve staking or multi-asset exposures; delays or requests for clarification are realistic hypotheses in the coming months.

Comparison with other crypto ETFs USA

  • Geographic focus: MRCA focuses exclusively on “Made in USA” tokens, differentiating itself from broad-market exposure funds or those focused on single assets like BTC or ETH;
  • Staking: the potential use of third-party providers to obtain rewards on PoS represents a point of discussion in the regulatory context, especially compared to the first spot ETFs, which generally do not include on-chain staking;
  • Direct exposure: like spot products on single assets, MRCA avoids derivatives and leverage, focusing on the “physical” replication of the index.

Impact for investors and market

  • Pro: greater transparency on the origin of the assets, regulated custody, periodic rebalancing, and selection curated by an independent committee;
  • Against: the geographical concentration and the exclusion of assets like BTC/ETH can reduce the market representativeness, in addition to the potential regulatory risks of staking and token classification, as well as the specific risks of individual protocols.

Frequently Asked Questions

Distinctive Points Compared to Other ETFs

MRCA stands out for its focus on US-origin tokens and for the requirement that assets be held at institutions regulated in the USA.

Frequency of index rebalancing

A quarterly rebalancing (every 90 days) is scheduled to update composition and weights based on the defined eligibility criteria.

Market Opportunity
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