What changed in this filing

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Item 1B. Unresolved Staff Comments

2026-03-31 compared with 2025-03-25 · 38 added, 22 removed, 4 unchanged (94% of the section changed)

Unresolved Staff Comments

Staff Comments

are no unresolved staff comments.

Cybersecurity

the Trust has no directors, principal officers or employees, the Sponsor is responsible for managing cybersecurity risks to the

The Sponsor has an information security program and policy in place, as mandated by new Regulation S-K Item 106.

is designed to assess, identify, and manage material risks from cybersecurity threats.

Regular reviews of cybersecurity and information

technology plans are conducted for key service providers, as part of the Sponsor’s disaster recovery and business continuity

planning process.

Additionally, the Sponsor evaluates whether any cybersecurity threats, including those resulting from previous

incidents, have materially affected or are reasonably likely to materially affect the Trust and the Fund.

Sponsor’s Vice President of IT & Cybersecurity , Mr.

Tiago DeMesquita, is responsible for identifying, assessing and

managing the Sponsor’s risks from cybersecurity threats.

DeMesquita has over 5 years of experience in technology and

cybersecurity.

DeMesquita heads the Cybersecurity Committee of the Sponsor which meets regularly to evaluate strategies, governance,

risk management, compliance, engineering and development, security operations, and incident management.

In addition, the Sponsor

maintains a cybersecurity insurance policy.

principal offices of the Sponsor, the Trust and the Fund are leased and are located at 234 West Florida Street, Suite 203, Milwaukee,

Wisconsin 53204.

Management and Strategy

Trust does not have any employees or a dedicated information technology infrastructure.

The Trust's cybersecurity risk management relies

on the programs and practices maintained by the Sponsor and the Trust's key third-party service providers.

Sponsor is part of the Hashdex group of companies, which includes Hashdex Gestora de Recursos Ltda.

("Hashdex Gestora"), a

Brazilian-regulated asset management firm that has adopted a formal Information Security and Cybersecurity Policy.

While this policy

is formally adopted at the Hashdex Gestora level, the Sponsor applies cybersecurity procedures and controls consistent with the principles

and standards set forth in that policy across its operations, including those relating to the Trust.

Sponsor's cybersecurity risk management processes are integrated into its overall risk management framework.

At least annually, the Sponsor

conducts a cybersecurity risk assessment to identify internal and external threats and evaluate the adequacy of existing controls, considering

potential financial, operational, and reputational impacts.

The Sponsor may engage specialized third-party firms to assist with these

assessments when deemed necessary.

Sponsor has implemented preventive and detective controls, including monitoring of workstations and network components, periodic vulnerability

and penetration testing, multi-factor authentication requirements, encryption protocols, employee cybersecurity training conducted at

least annually, and an incident response framework aligned with its Business Continuity Plan.

Sponsor also maintains processes to oversee and identify material cybersecurity risks associated with the Trust's use of third-party

service providers.

Prior to engaging third parties that will have access to confidential information or systems, the Sponsor conducts

a cybersecurity due diligence evaluation assessing, among other things, whether the third party maintains formal information security

policies, an incident response plan, adequate data protection mechanisms, and all necessary certifications.

These evaluations are periodically

reassessed and the Sponsor includes information security requirements in its service agreements.

of December 31, 2025, no cybersecurity threats or incidents, including as a result of any previous cybersecurity incidents, have materially

affected or are reasonably likely to materially affect the Trust, including its business strategy, results of operations, or financial

Trust is organized as a Delaware statutory trust and does not have a board of directors.

The Sponsor is solely responsible for the management

and control of the Trust's business and affairs, including oversight of cybersecurity risks.

Sponsor has established a risk and compliance committee (the "Risk & Compliance Committee"), composed of the head of the

risk and compliance function and the risk and compliance team.

The Risk & Compliance Committee meets at least quarterly and is responsible

for the supervision and monitoring of cybersecurity practices applicable to the Sponsor's activities, including those relating to the

Legal Proceedings

the Trust, Fund or Sponsor are currently subject to any material legal proceedings, nor, to our knowledge, are any material legal

proceedings threatened against Trust, Fund or Sponsor.

the Trust, the Fund or the Sponsor are currently subject to any material legal proceedings, nor, to our knowledge, are any material legal

proceedings threatened against the Trust, the Fund or the Sponsor.

Mine Safety Disclosures

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 1B. Unresolved Staff Comments