OranjeBTC, Brazil's largest Bitcoin treasury firm, filed registration for the DIGY11 exchange-traded fund with a structure that routes 95% of portfolio assets into Strategy (STRC) shares rather than direct bitcoin custody. The filing, first reported by Coinpedia, marks the first Brazilian ETF to use Strategy's balance sheet as its primary bitcoin proxy.
Strategy holds approximately 226,500 BTC on its balance sheet, the largest corporate bitcoin position globally. By allocating 95% to STRC, DIGY11 effectively offers Brazilian investors exposure to that hoard through a regulated equity wrapper. The remaining 5% will sit in cash equivalents for liquidity management.
The structure sidesteps Brazil's current regulatory framework, which does not yet permit ETFs to hold bitcoin directly. CVM, the Brazilian securities regulator, has approved futures-based and foreign equity-wrapped products but has not authorized spot bitcoin custody for local funds. OranjeBTC's approach mirrors the path taken by Hashdex and QR Asset Management, which launched bitcoin futures ETFs in 2021 and 2022 respectively.
| Metric | DIGY11 (Proposed) | HASH11 (Hashdex) | QBTC11 (QR Asset) |
|---|---|---|---|
| --- | --- | --- | --- |
| Primary Holding | Strategy (STRC) 95% | CME Bitcoin Futures | CME Bitcoin Futures |
|---|---|---|---|
| Direct BTC Custody | No | No | No |
| Expense Ratio | Not disclosed | 1.0% | 0.95% |
|---|---|---|---|
| Launch Year | 2024 (pending) | 2021 | 2022 |
| Regulatory Path | Foreign equity wrapper | Futures-based | Futures-based |
BTC traded at $63,575 with 24-hour volume of $20.7 billion at the time of the filing, according to CoinGecko data. The cryptocurrency's dominance stood at 56.3% of the $2.27 trillion total crypto market cap. Strategy shares closed at $134.20 on the NASDAQ, implying a per-share bitcoin exposure of roughly 0.001 BTC at current prices.
Custody and Mandate Implications
The DIGY11 structure raises questions about tracking error. Strategy trades at a persistent premium to its net asset value — approximately 1.8x as of the latest close — meaning DIGY11 investors will pay that premium indirectly. The fund's 5% cash buffer also creates drag during bitcoin rallies. For institutional allocators with mandates requiring direct custody or NAV-aligned exposure, the product may fall short.
OranjeBTC has not disclosed an expense ratio or seeding capital. The firm manages over R$500 million in bitcoin-denominated treasury assets for corporate clients, according to its latest investor presentation. CVM review typically takes 60-90 days for new ETF registrations, placing a potential launch in Q4 2024 if no objections arise.
The next catalyst is CVM's formal response to the registration. Market observers will watch whether the regulator accepts the foreign equity wrapper as compliant with existing rules or demands modifications. A parallel track: Strategy's next quarterly disclosure, expected in early November, will update its bitcoin holdings and may influence DIGY11's effective exposure. If approved, DIGY11 would become the fifth bitcoin-linked ETF on B3, Brazil's stock exchange, joining HASH11, QBTC11, BITC11, and the recently launched BITO11 futures product.