Strategy turned MSCI's own regulatory history against the index provider on Aug. 31, filing a comment letter that cites MSCI's 2021 correspondence with the SEC to argue that excluding MicroStrategy from major indexes would be inconsistent with the firm's prior position on bitcoin as a treasury asset. Company Digital Assets (est.) T12M Revenue Asset/Revenue Ratio MicroStrategy $19.5B $120M 162x Coinbase $1.2B $5.6B 0.21x Block $0.8B $22.3B 0.04x Marathon Digital $1.1B $620M 1.8x The dispute centers on MSCI's proposed non-operating company screen, unveiled in July as part of a broader methodology consultation. Market data shows under the new framework, companies deriving more than 50% of their market value from non-operating assets, including digital assets held as treasury reserves, could be reclassified and removed from flagship indexes like the MSCI USA and MSCI ACWI. MicroStrategy, which holds 252,220 bitcoin valued at roughly $19.5 billion at current prices, is the primary target.
**The 2021 letter MSCI wrote to the SEC** In a letter dated June 2021 responding to the SEC's request for comment on digital asset custody, MSCI wrote that bitcoin "should be considered a legitimate treasury asset for corporate balance sheets" and that "the classification of digital assets as non-operating would be inconsistent with evolving corporate finance practices." Strategy's Aug. 31 filing quotes this passage directly, arguing that the proposed screen now treats bitcoin holdings as evidence of a non-operating business model, a direct reversal. MSCI has not publicly responded to the specific citation. The index provider's consultation document acknowledges that "certain stakeholders have raised concerns about the treatment of digital asset treasuries" but maintains the screen is designed to "improve index representativeness by excluding shell-like entities. **What the screen actually does** MSCI's methodology proposes a two-step test. First, it calculates the ratio of non-operating assets (cash, investments, digital assets) to total enterprise value.
判定基準（スクリーニング）はMicroStrategy特有のものではありません。 - "Coinbase, Block, and Marathon Digital each hold material bitcoin or digital asset positions relative to their operating revenues." -> Coinbase、Block、Marathon Digitalはいずれも、営業収益に対して相当な規模のビットコインまたはデジタル資産のポジションを保有しています。 - "MSCI's consultation paper lists 14
1, down 1.5% in 24 hours and 1.6% over the past seven days. The 7-day closes show a range of $77,523 to $79,647. **The procedural clock** MSCI's consultation period closes Sept. 30. The index provider typically publishes final methodology decisions 4-6 weeks after consultation closes, with implementation at the next semi-annual index review, currently scheduled for Nov. 2026. If adopted as proposed, the first rebalancing would occur after U.S. markets close on Nov. 27, 2026. Strategy's letter requests either a carve-out for "digital assets held as primary treasury reserves by operating companies" or a delay until the FASB's fair-value accounting rules for digital assets take effect in fiscal 2025, which would bring unrealized gains onto the income statement and change the optics of the asset-to-revenue ratio. Per market reports, **What happens to the $24 billion** Passive funds tracking MSCI USA and ACWI would be forced to sell MSTR shares ahead of the November rebalance. Figures from the desk show at current index weights, MSTR represents roughly 0.12% of MSCI USA and 0.04% of ACWI.
Market data shows the $24 billion figure aggregates estimated assets under management in funds and ETFs that replicate these indexes, not all of which would trade simultaneously, but the cumulative flow would be material relative to MSTR's average daily volume of $2.8 billion. Per market reports, microStrategy shares closed at $134.72 on Aug. 29, down 3.2% for the week. Options markets show elevated put skew for the November expiry, with the $120 strike trading at a 12% implied volatility premium to calls, a signal that hedgers are pricing exclusion risk. MSCI's own 2021 SEC letter creates a credible procedural vulnerability for the proposed screen, but the index provider retains discretion to finalize methodology changes, and the comment period closes in 29 days.