Reexamination of different DAT strategies in the context of Nasdaq’s regulatory tightening

Author: @BlazingKevin, Movemaker Researcher; Source: @MovemakerCN

Nasdaq announced new regulatory measures for digital asset companies last Thursday.Specifically, if such companies want to fund their cryptocurrency procurement by issuing new shares, the plan must be submitted to the shareholders’ meeting for voting to ensure investors’ right to know.

This undoubtedly poured cold water on the crypto market, because the “DAT strategy” is regarded by many people as the latest wealth password.From an external perspective, it is like a simple and crude financial tool: a company raises funds through listing, buys coins, and then relies on market rise to achieve positive feedback on its stock price.In a short period of time, this model quickly ignited public opinion and was even packaged as a “financial technique” that Wall Street conspired with the crypto circle.Judging from the market performance, BTC-related DATs have encountered a brief cold wave, and the ETH narrative seems to have finished the first roller coaster, while SOL’s treasury model seems to be ready to go.What kind of logic and risks are hidden behind the glamor?

The development model of DAT enterprises

The core idea of ​​DAT (Digital Asset Treasury)It is not complicated: listed companies obtain funds by issuing new shares, and then directly use the raised cash to buy cryptocurrencies in the market, filling the balance sheet with mainstream tokens such as BTC, ETH, and SOL.In an ideal cycle, companies can repeatedly perform a spiral operation of “financing – buying coins – rising coin prices – rising stock prices – refinancing”, like a capital accelerator that can be infinitely superimposed.

To make this narrative self-consistent, there are usually three paths for treasury operations:

  1. Business skin replacement: The company on the verge of bankruptcy has transformed into a “crypto financial service provider”, such as binding to the new narrative through pledge or income strategies.

  2. Mergers and acquisitions: Put a private enterprise focused on crypto business into a listed shell company to obtain a compliant identity at a low cost.

  3. SPAC mode: Use special purpose to acquire a company and enter the capital market as a “shortcut”.

The first two methods are not new, and what is really being re-appreciated is the SPAC tool that was once used by Circle.The charm is that even if there are no customers, products, or even mature business logic, as long as you can pile up Bitcoin on the books, you can quickly put the exchange’s stock code and sell the Bitcoin dividends to public investors in the most direct way.

This approach is very different from Strategy’s strategy back then.The latter at least strives to emphasize the “store of value” attributes of BTC, and new players nowadays almost buy all the mainstream tokens first and then make up a business story temporarily.This type of company is more like hedge funds wearing the guise of a listed company, but it can still attract batches of capital chasing crypto assets to enter.

The true value of SPAC is not just about getting companies to go public quickly bypassing the lengthy IPO process.The key point is that companies can sell imaginative plans to investors in the absence of actual business—such as “BTC holdings will be rushing $1 billion by the end of the year.”In this process, the founding team can even bring giants like Galaxy to participate in PIPE (publication private equity financing) in advance and lock in amazing valuations before the merger.The SEC regulations are ostensibly followed, but in essence they avoid the sensitive identity of “investment funds”.

More importantly, SPAC gives companies the opportunity to take advantage of leverage in an extremely early stage: first hoard coins, then double purchase through equity or debt financing, and use crypto assets as the bottom layer to continuously amplify firepower.This mechanism allowed the founders to completely bypass the traditional path of “building products first, then proving value” and directly drive growth with narratives and financial tools.Compared to IPO, SPAC gives them more room for imagination and freedom of trading.

A combination of PIPE and convertible bondsIt is an important addition to the entire script:

  1. Find a suitable shell company or SPAC first.

  2. Join forces with it to tailor-design a crypto asset reserve strategy.

  3. Cooperate with investment banks to issue PIPE and convertible bonds, and sell shares directly to institutions.

  4. PIPE often sells stocks with discounts, leaving institutions with arbitrage space.

  5. Convertible bonds protect investors’ downside risks while providing some rising returns, becoming the first choice for stable funds.

Unlike Strategy’s original “anti-inflation reserve” narrative, today’s PIPE players are more radical. They not only buy coins, but also superimpose pledges, borrowing and other operations to release book returns faster.The reaction of the secondary market is also extremely direct: whenever such transactions are disclosed, the company’s stock price often rises several times instantly.For Wall Street, this is proficient in financial packaging – translating “buying coins” into a complex financial structure, and then charging expensive premiums from investors by relying on information asymmetry.

Of course, not all companies are eyeing large-cap coins such as BTC, ETH, and SOL.For smaller companies, the top 50 mid-tail tokens are the more exciting targets.They fluctuate violently and have amazing potential returns, attracting a number of small treasury companies to enter the market to gamble, but more often they are just flash in the pan and are finally cleaned up by the market.

How are DATs such as ETH and SOL different from BTC?

The company’s background of holding cryptocurrencies is becoming increasingly diversified and is no longer limited to the crypto-native industry.For example, among BTC holders, there are traditional business companies like Strategy and Metaplanet (hotel real estate), which use Bitcoin as a strategic reserve for value storage; and companies closely related to the industry such as Mara (intellectual property/mining) and Bullish (digital asset trading).

BTC DAT encounters a cold wave, but mNAV is the most stable

In August this year, Strategy’s share price fell by 16.8%, and the company’s valuation premium enjoyed by Bitcoin holdings over the years was almost swallowed up.This is not a simple stock price adjustment, but more like a prelude to the gradual loss of the aura of the Bitcoin corporate treasury story.

In fact, as emerging DAT strategies such as Ethereum gradually gain a foothold, Strategy, the “first mover”, is being diluted.What is even more fatal is the turning point in financing methods.The company planned to purchase Bitcoin through preferred stock financing, but raised only US$47 million, which is far lower than the outside world’s expectations.The funding gap forces it to restart the issuance of common stock, which undoubtedly breaks the previously promised “control dilution” principle.In the capital market context, this means loss of credibility.

This kind of turning point is not an isolated case.It is not difficult to observe the flow of funds in BTC, ETH and SOL. The market is diversifying, and Bitcoin treasury companies are the first to feel the pressure of funds being diverted.As the first group to try this model, they have also entered the adjustment and labor pain period first.Today, about one-third of listed companies holding Bitcoin have their share prices even lower than the value of Bitcoin on their books.This is especially fatal for small businesses: liquidity tightness makes every equity financing extremely difficult, and the heavy interest on convertible bonds and the near repayment period further compress the living space.

Companies that can really run often have two commonalities. One is that the community consensus is strong enough, and the other is that they can continuously increase the “bitcoin holdings per share” and build financial projects around it.On the contrary, most companies that lack continuous strategic support will be eliminated by the market.For example, SOS Limited, after transforming from crypto mining to commodity trading, not only did its main business fall into trouble, but its Bitcoin strategy was also unsustainable, and eventually lagging far behind its peers.It can be seen that the model of “heavy bitcoin holdings” is more popular among the market than “symbolic allocation”.

Of course, such companies are still facing the impact of extreme fluctuations.When a company’s net assets are higher than its market capitalization, there may be a reversal opportunity, but for companies with financial stakes, it is obviously difficult to change the fate of bankruptcy simply by retaining a small amount of Bitcoin on the books.What’s more, when the enterprise strategy expands to the tail tokens, the risk is even doubled.This type of assets lacks the hard asset attributes of Bitcoin and the stable buying support, and is very likely to collapse first when the market adjusts.

ETH DAT returns diversified, but mNAV is fully discounted

Judging from the latest Strategic ETH Reserve data, more than 70 companies, listed companies or institutions around the world have included ETH in their strategic reserves (more than 100 single positions).The total holdings have exceeded 4.7 million pieces, which is about US$20 billion in market value, accounting for 3.89% of Ethereum’s total supply.Among them, there are about 14 companies that have clearly disclosed the “Ethereum treasury strategy”, with a total holding of nearly 3 million ETH, worth about US$12.86 billion.

Unlike the “single holding” that Bitcoin treasury companies mainly adopt, these companies entering the ETH treasury track show significant differentiation in asset utilization models.Its strategies can be roughly divided into four categories: one is the “entrusted type” that relies on third-party pledge services to obtain stable returns; the other is the “self-operated type” that is directly embedded in the network through self-operated nodes and liquid staking; the more radical type will combine lending, liquidity supply, and MEV optimization operations to maximize capital efficiency; and the other part is exploring advanced leverage strategies such as revolving loans to try to amplify asset returns.

Among the current holding companies, the trends of the top five are particularly representative:

  • BitMineIt became the largest corporate holding party just two months after the launch of the ETH treasury strategy, with holdings jumping to more than 1.52 million, targeting 5% of the total ETH supply.It is worth noting that Peter Thiel has acquired a 9.1% stake.If pledge is initiated in the future, the profit potential is extremely considerable.

  • SharpLink GamingOriginally a sports bookmaker, it officially positioned ETH as a core reserve asset in June and introduced Ethereum co-founder Joseph Lubin as chairman of the board.Its holdings are close to being fully pledged, forming a stable source of passive income.

  • The Ether MachineThrough the SPAC merger, the planned position is more than US$1.5 billion ETH. The management publicly stated that it will focus on pledge, re-staking and DeFi operations, and even mentioned trying revolving loans on Aave.

  • Bit DigitalThe transformation from a traditional mining company to an Ethereum asset management and pledge platform has been completed, and the strategic positioning is clear.

  • ETHZillaThe transition from biotechnology to the entertainment and gaming industries, while developing ETH-related cumulative tools, Peter Thiel’s investment team also appeared behind it.

Overall, the logic of the ETH treasury is different from that of Bitcoin.The core value of Bitcoin is more reflected in the positioning of “reserve assets”, and the advantage of ETH lies in its native income channels.Ethereum pledges currently have a nominal rate of return of approximately 2.95%, and its inflation-adjusted real rate of return is 2.15%.If 30% of the total holdings of existing companies are pledged and the ETH price remains at US$4,000, the corresponding annualized income scale is approximately US$79 million.This figure reflects that ETH treasury companies can obtain relatively stable cash flows beyond price fluctuations.

At the operational level, there are two main paths for enterprises to choose: one is to directly run the verification node; the other is to use liquid staking protocols (such as Lido, Coinbase, RocketPool).The U.S. SEC has made it clear that such agreements are not recognized as securities, clearing compliance barriers for institutional participation and enabling them to obtain additional liquidity tokens as derivative assets.

These derivative assets, such as Lido’s stETH, are highly composable in the DeFi market and can be further used as lending or liquidity mining tools.Taking Aave v3 as an example, its ETH and stETH fund pools have exceeded 1.1 million ETH.As more corporate treasury funds flow in, the volume of this fund pool is expected to continue to expand, thereby significantly enhancing market liquidity while increasing yields.

The core competitiveness of ETH DAT lies in the hierarchy and scalability of its revenue structure.This makes it show a stronger latecomer advantage in comparison with Bitcoin DAT.

SOL DAT wants to come from behind, but it is still small

More and more listed companies are starting to put SOL on their balance sheets.Currently, Solana has a total market value of approximately US$107 billion. According to data, the total number of SOLs in the hands of listed companies is more than 4 million, worth more than US$800 million.But the stock prices of these companies are not pretty, which may be because Solana’s reserve market has not yet shown a real leading strategy, and because the SOL ETF has not passed the approval.

However, a new wave of capital is joining.Now listed companies only hold SOLs 0.69% of the circulating supply, while Pantera Capital recently promised to invest $1.25 billion, and Galaxy, Multicoin and Jump jointly promised to invest $1 billion, which totals 3.5 times the holdings of existing listed companies.

More specifically, Galaxy, Multicoin and Jump intend to build a digital asset finance company focused on Solana by acquiring a public company.Pantera, led by former Tiger Management executive Dan Morehead, also plans to raise $1.25 billion to acquire a Nasdaq-listed company and turn it into an investment company focused on SOL, with the tentative name “Solana Co.”You know, Pantera and Galaxy previously bought a lot of SOLs at low prices from bankrupt FTX, making a lot of money.Simply put, their new move now can be understood as – making enough money and preparing to increase the bet.

The rise of the DAT company model is a brand new and advanced way of capturing value for these institutions.Through DAT, they can not only hold SOL and wait for the price to rise, but also earn some profits through various DeFi protocols to achieve multiple asset appreciation.

From the trend of Bitcoin in the past two years, it can be seen that when institutions begin to systematically accumulate certain crypto assets, this asset will often enter a relatively stable upward channel.The Ethereum example has shown this.The difference between Solana and Ethereum DAT companies is also obvious: a large part of the reason why institutions choose ETH is because it is decentralized, while Solana is attracted by its public chain attributes and its application potential for users.

If we look at the efficiency of DAT’s absorption of transaction supply, the $2.5 billion SOL DAT program brought by Galaxy and Pantera is equivalent to the scale of financing of ETH of $30 billion or BTC of $91 billion.SOL DAT is more efficient than ETH for two reasons: First, the circulating supply does not equal the tradable volume. Currently, Solana has 63.1% of tokens pledged, and few can actually trade in the market; while the ETH pledge rate is only 29.6%, the tradable volume is large, and the price is more difficult to promote.The second is the relative capital impact. SOL’s market value is much lower than ETH and BTC. From the perspective of relative valuation, the effect of investing USD 1 to SOL DAT is far greater than the same investment in ETH and BTC.

Moreover, with the expected adoption of SOL ETFs by the end of this year, the driving effect of this buying behavior on price may be more obvious.

DAT expectations for BNB and a number of tail assets

BNB DAT

CEA Industries: Targeting 1% of BNB total supply

CEA Industries (stock code: BNC) recently announced that it has increased its BNB holdings to 388,888, with a market value of approximately US$330 million.The company plans to reach 1% of the total BNB supply by the end of 2025, or about 10 million BNBs.The move highlights its use of digital assets as part of its core strategy, similar to MicroStrategy’s strategy in the Bitcoin space.In addition, CEA Industries partnered with 10X Capital to accept $500 million in private investment from YZi Labs, including $400 million in cash and $100 million in crypto assets to further expand BNB reserves.

Nano Labs: Steadily increase BNB reserves

Nano Labs (NASDAQ:NA) currently holds about 128,000 BNBs, with an average acquisition cost of $713 each, and a total market value of about $108 million.The company added 8,000 BNBs through OTC, showing its commitment to BNB as a long-term value reserve.This strategy may lay the foundation for its further layout in the digital asset field.

Liminatus Pharma: Established a subsidiary of “BNB Strategy in the United States”

Liminatus Pharma (NASDAQ:LIMN) plans to raise up to $500 million in phases in the next few years through its newly formed subsidiary, American BNB Strategy, to strategically invest in BNB.This move marks the active embracing of digital assets by traditional biopharmaceutical companies and exploring the possibility of incorporating BNB into their asset allocation.

Windtree Therapeutics: US$520 million in financing for BNB strategy

Windtree Therapeutics (NASDAQ:WINT) announced plans to raise up to $520 million in funding, 99% of which will be used to purchase BNB to enhance its digital assets.The company has entered into an agreement with Kraken as its BNB-held hosting provider.This move shows the active transformation of traditional biotech companies in the digital asset field.

Huaxing Capital: The first listed company in Hong Kong to directly hold BNB

Huaxing Capital signed a memorandum with YZi Labs in August 2025, planning to invest US$100 million to purchase BNB, becoming the first Hong Kong listed company to directly hold BNB.In addition, Huaxing Capital also plans to launch compliant BNB fund products and establish BNB-based stablecoins and on-chain RWAs.

B Strategy: To raise $1 billion to establish BNB Treasury

B Strategy plans to go public in the United States, establishing a Treasury company focused on BNB investment, with a target of raising $1 billion.The company has received strategic support from YZi Labs.

Amber International and Hash Global: Launching BNB Fund

Amber International (NASDAQ: AMBR) partnered with Hash Global to launch the BNB fund, aiming to use its $100 million crypto assets reserve for BNB investments.As a blockchain-native income product, the fund aims to provide institutional investors with a stable source of returns.

DAT layout of Ethena and SUI

Ethena (ENA): StablecoinX and Mega Matrix’s strategic investment

Ethena’s native token ENA is attracting the attention of institutional investors.StablecoinX plans to raise $895 million through a SPAC merger to reserve ENA tokens.In addition, Mega Matrix has filed a $2 billion structural registration statement with the U.S. Securities and Exchange Commission (SEC) for reserves of USDe and ENA.

SUI: The strategic layout of Sui Group Holdings

Sui Group Holdings is the only company to go public and backed by the Sui Foundation, holding approximately 102 million SUI tokens with a market value of approximately US$345 million.The company plans to continue to raise funds through capital to purchase more discounted locked SUI tokens to increase SUI holdings per share to create value for shareholders.

Whether non-mainstream DAT can have sufficient influence or even continue to produce forward flywheels. The most important thing is not whether mNAV is always greater than 1, and it is in a premium state:mNAV may fall below 1, resulting in the occurrence of discounts. However, for these companies, selling crypto assets at discounts is even more accelerating the death.

The core direction of evaluating non-mainstream DATs should be financing capabilities and buying capabilities:

The former represents the degree of optimism and confidence in the crypto assets. Whether the company has good financing channels can still buy when the crypto assets enters a downward cycle. This is the best endorsement of DAT companies. The positive effects generated by financing scale can promote mNAV to a certain extent. Observing the DAT process of the above three crypto assets, BNB and Ethena’s DAT companies have very strong and extensive financing capabilities, which are more likely to promote the positive development of currency stock prices in the long run.

Secondly, the ability to buy continuously is also the key point. Performing its investment strategy continuously and disciplinedly and proving its research and timing ability to the market is the basis for building a brand and winning premiums.When the discount occurs, there is enough ammunition to continue to buy, which is the best injected confidence to prove to the market.

BNB, Ethena and Sui have not yet experienced this stage, but when the FOMO of mainstream DAT came to an end, whether DAT companies with tail assets can survive, besides the above two factors, whether they can provide more asset gameplay for encryption protocols may be a watershed in the competition of tail DAT: Wall Street only brings incremental funds, and how to amplify leverage on the market is the focus of leverage. How to maximize asset efficiency, innovation in programmable liquidity, multi-dimensional value capture, etc. Precision financial engineering and real returns will make the leaders of tail DAT stand out.

Look at DAT flywheel rationally

DAT is not a high-end financial innovation, it is essentially more like a regulatory arbitrage tool: when the existing crypto asset supervision is not yet fully clear, Wall Street or some listed companies can quickly allocate crypto assets through the DAT architecture.On the surface, this wave of DAT craze is a strategic layout that imitates MicroStrategy, but the core driving force comes more from the market FOMO sentiment when the official regulatory channels are still loose.In other words, the DAT prosperity has a distinct short-term speculative color, and its sustainability depends on the dual impact of market sentiment and regulatory policies.

In terms of flywheel mechanism, DAT can amplify returns during the bull market: asset market value rises, mNAV premium increases, liquidity increases, forming a positive feedback loop.However, once the market reverses, this mechanism will also amplify risks.When mNAV discount or premium disappears, some DAT companies may be forced to liquidate their assets, triggering chain selling pressure, thereby amplifying short-term price fluctuations.The complex structure of DAT is aggravated while attracting institutional funds, which also exacerbates information asymmetry, making it difficult for retail investors to fully understand the risk exposure and the true value of assets.

From the perspective of valuation logic, DAT may bring the market back to the “story-driven” stage: prices rely more on market expectations, concept popularity and institutional participation in the short term.Hot money entry may push up prices, but this rise lacks underlying value support.Although the rise of Ethereum DAT is expected to drive on-chain staking, DeFi activity and ecological participation, its long-term impact on corporate profits and overall ecological health is still highly uncertain.

Overall, DAT flywheels can create short-term returns and market attention when the market is booming, but investors need to rationally understand their limitations: high leverage amplifies upward returns and also amplifies downward risks, and regulatory pressure, liquidity tightening and mNAV discounts are all key factors that may break this inflated structure at any time.

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