Osprey Bitcoin Trust 10-K

ITEM 1B. UNRESOLVED STAFF COMMENTS None. ITEM 1C. CYBERSECURITY Cybersecurity Risk Management and Strategy The Trust does not have any officers, directors or employees. The Sponsor, an affiliate of REX Financial, LLC (“REX Financial”), is responsible for the oversight and overall management of the Trust. The Sponsor relies on REX Financial’s cybersecurity framework for the Trust’s cybersecurity risk management and strategy, and REX Financial uses a third-party service provider to oversee and implement the cybersecurity program. REX Financial’s enterprise-wide cybersecurity risk management policies and procedures are informed by industry standards, and they are designed to address cybersecurity risks identified by external auditors and assessors, threat intelligence providers, internal stakeholders, vulnerability management programs and security management programs. REX Financial’s cybersecurity risk management program is designed to be aligned with its business strategy. It shares common methodologies, reporting channels and governance processes that apply to other areas of enterprise risk, including legal, compliance, strategic, operational and financial risk. Governance Related to Cybersecurity Risks The cybersecurity risk management program and related operations and processes are delegated to a third-party service provider specializing in information technology and cybersecurity management. The current third-party service provider is compliant with Service Organization Controls Type II reporting and provides engineers, technicians, and specialists who average more than 10 years’ experience in vital areas. The Sponsor’s senior officers regularly review firm management and issues, including cybersecurity issues (if any). Any incidents identified by the third-party service provider are elevated to the Sponsor’s Chief Compliance Officer and discussed with other senior officers of the Sponsor. As of December 31, 2024, cybersecurity risks have not materially affected the Trust’s business strategy, results of operations or financial condition. However, the Trust can provide no assurance that there will not be cybersecurity threats or incidents in the future or that they will not materially affect the Trust. For more information regarding the risks the Trust faces from cybersecurity threats, see Item 1A. “Risk Factors” included in this Annual Report. ITEM 2. PROPERTIES Not applicable. ITEM 3. LEGAL PROCEEDINGS None. ITEM 4. MINE SAFETY DISCLOSURES Not applicable. 61 PART II