CTF Written Submission

Re: Responsible (Native) Staking Framework for Solana Exchange Traded Products

Dec. 11, 2025
  • The framework proposes that Solana-based ETP issuers provide periodic public disclosures detailing validator allocations, concentration policies, and incidents, enabling the SEC to monitor systemic risks without prescribing protocol-level changes.
  • The SEC is urged to formally acknowledge that stake concentration in Solana ETPs poses material investor protection risks, including transaction censorship, governance capture, and network halts, thereby falling squarely within its jurisdiction.
  • Validators receiving ETP stake must disclose governance voting intentions and maintain independence from issuers and custodians to prevent proxy-advisory style influence and ensure fair market access.

Last Reviewed or Updated: Dec. 11, 2025