Hashdex Commodities Trust

Hashdex Commodities Trust: A Significant Leadership Transition

Investors in the Hashdex Commodities Trust need to be aware of a major shift in leadership. This summary cuts through the legal jargon to explain a recent, critical development: a change in the Trust's sponsor, which impacts its strategic direction and future.

1. Event Description: What is the core event?

The Hashdex Commodities Trust, previously known as Tidal Commodities Trust I, underwent a major change in its management. Tidal Investments, LLC ("Tidal") stepped down as the Trust's sponsor, and Hashdex Asset Management Ltd. ("Hashdex") assumed this key role. As the new sponsor, Hashdex now fully manages the Trust's strategy, operations, and overall direction.

This transition is especially important because the Trust now prominently features the Hashdex Bitcoin ETF (trading under the ticker DEFI). This change in sponsorship represents a complete shift in leadership and operational control, which will impact the fund's future.

2. Event Date/Timeline: When did this change become effective?

The sponsorship change took effect immediately after the close of trading on January 15, 2026. Hashdex publicly disclosed this event in an 8-K filing with the SEC on January 16, 2026. This transition was not unexpected; Hashdex had previously announced it in an SEC filing dated October 29, 2025. Tidal and Hashdex executed a "Sponsorship Transfer Agreement" on October 27, 2025, which outlined the terms of this handover.

3. Impact Assessment: Who/what is affected and why did this transition occur?

The sponsor is the party responsible for setting the investment strategy, overseeing service providers, and making key decisions for the fund. Tidal stepped down, and Hashdex assumed the sponsor role as part of a strategic agreement between the two companies. Hashdex, known for its expertise in digital assets, can now align the Trust's operations and investment strategy with its core vision, particularly emphasizing its digital asset offerings.

This change has several key implications:

• New Leadership, Defined Strategy: With Hashdex at the helm, the Trust operates under new leadership and a potentially refined investment strategy. Given Hashdex's focus, this likely emphasizes digital assets, especially Bitcoin through the DEFI ETF. Investors should review the updated prospectus to understand the precise investment mandate.
• Primary Focus on Bitcoin (DEFI): The filing prominently features the Hashdex Bitcoin ETF (DEFI), strongly suggesting it will be a central, if not primary, component of the Hashdex Commodities Trust. Investors who previously sought exposure to a broad range of traditional commodities should be aware of this potential shift towards digital assets.
• Operational Reset: Hashdex terminated all prior agreements with service providers (such as marketing agents, custodians, fund accountants, and transfer agents) that were tied to Tidal's sponsorship. Hashdex will establish new agreements, creating a complete operational reset for the Trust.
• Control and Decision-Making: Hashdex now holds ultimate control over the Trust, dictating its management, investment decisions, and future.
• Altered Risk and Return Profile: Hashdex's specialization in digital assets introduces a different risk and return profile compared to traditional commodities. While digital assets like Bitcoin offer potential for growth, they are subject to significant price volatility, regulatory uncertainty, evolving market infrastructure, and cybersecurity risks. Investors should carefully consider these factors.

Who does this change directly impact?

• Investors in Hashdex Commodities Trust (and the DEFI Bitcoin ETF): A new sponsor with a distinct strategic focus now manages your investment. Understanding the updated investment objectives and risks is crucial.
• Hashdex Management Team: They are now directly responsible for the Trust's performance and operational integrity.
• Former Tidal Management: Key officers from Tidal previously involved with the Trust no longer manage it.
• Service Providers: Hashdex will implement new or renegotiated agreements for critical functions like custody, accounting, and administration.

4. Financial Impact: What is the financial impact?

The sponsorship transition directly impacts the Trust's financial structure and operational costs.

• Management Fees: As the new sponsor, Hashdex will receive a management fee for its services. The Trust's updated prospectus details the specific percentage and structure of this fee; investors should review it.
• Sponsorship Transfer Agreement: The "Sponsorship Transfer Agreement" between Tidal and Hashdex outlined the terms of this handover. While such agreements often involve financial considerations, the public filing doesn't provide specific financial details about this particular transfer.
• Operational Expenses: With Hashdex terminating prior service agreements and establishing new ones, the Trust's operational expenses for custody, administration, marketing, and other services may change. Investors should consult the updated prospectus for details on the new fee structure and expense ratios.

5. What are the next steps and future outlook?

Here are the next steps and future outlook:

• Full Integration: Hashdex will continue integrating its management and operational processes for seamless oversight of the Trust.
• New Service Agreements: Hashdex will finalize all necessary service agreements under its structure.
• Market Monitoring: Investors and the market will closely observe the performance and strategic decisions of the Trust, particularly the Hashdex Bitcoin ETF (DEFI), under Hashdex's full control.
• Ongoing Disclosures: Hashdex will provide further detailed reports and updates on the fund's composition, performance, and any strategic adjustments.

6. Key Takeaways for Investors:

Here are the key takeaways for investors:

• Understand the New Management: Understand that the Trust's management and strategic direction shifted fundamentally from Tidal to Hashdex.
• Re-evaluate Investment Alignment: Given the strong emphasis on the Hashdex Bitcoin ETF (DEFI), assess whether this focus on digital assets aligns with your personal investment goals, risk tolerance, and long-term financial strategy. If your primary interest was in traditional commodities, this change requires a thorough review.
• Consult Official Documents: You must review the updated prospectus and other official filings from Hashdex to understand the precise investment mandate, fee structure (including the management fee), and detailed risk factors.
• Monitor the Digital Asset Market: If your investment is now primarily exposed to Bitcoin, staying informed about cryptocurrency market trends, regulations, and technological advancements is crucial.
• Due Diligence is Key: This is a significant change. Take the time to conduct your due diligence to ensure your investment continues to meet your objectives.