Re-examination of Different DAT Strategies Against the Background of Tightened Nasdaq Regulation

Author: @BlazingKevin_, the Researcher at Movemaker

NASDAQ announced new regulatory measures for digital asset companies last Thursday. Specifically, if such companies wish to fund their cryptocurrency purchases by issuing new shares, the plan must first be submitted for a shareholder vote to ensure investors' right to know.

This undoubtedly dampened the crypto market, as the "DAT strategy" is seen by many as the latest wealth code. From an external perspective, it appears to be a blunt financial tool: companies raise funds through public offerings, use the money to buy coins, and then rely on market appreciation to achieve positive feedback on their stock prices. In a short time, this model has rapidly ignited public opinion, even being packaged as a "financial gimmick" conspired between Wall Street and the crypto circle. From market performance, BTC-related DAT has encountered a brief cold wave, the ETH narrative seems to have completed its first roller coaster ride, while SOL's treasury model appears to be gearing up. What kind of logic and risks are hidden behind this glamour?

Development Model of DAT Enterprises

The core idea of DAT (Digital Asset Treasury) is not complicated: public companies raise funds by issuing new shares, then directly use the cash raised to buy cryptocurrencies in the market, filling their balance sheets with mainstream tokens like BTC, ETH, and SOL. In an ideal cycle, companies can repeatedly perform the spiral operation of "financing---buying coins---coin price rising---stock price rising---refinancing," as if they are a capital accelerator that can infinitely compound.

To make this narrative coherent, treasury operations typically have three paths:

1. Business Rebranding: Near-bankrupt companies transform into "crypto financial service providers," for example, binding themselves to new narratives through staking or yield strategies.
2. Mergers and Acquisitions: A private company focused on crypto business is placed inside a public shell company to obtain compliance status at a low cost.
3. SPAC Model: Utilizing a Special Purpose Acquisition Company to enter the capital market as a "shortcut."

The first two methods are not new, while the real tool being brought back to the forefront is the SPAC tool once used by Circle. Its charm lies in the fact that even without customers, products, or mature business logic, as long as the balance sheet is filled with Bitcoin, it can quickly list on an exchange with a stock code, directly packaging Bitcoin dividends for public investors.

This approach is vastly different from the strategy of the past. The latter at least emphasized BTC's "store of value" attribute, while the new players almost buy up mainstream tokens first and then temporarily fabricate a business story. These companies resemble hedge funds dressed in public company attire, yet still manage to attract waves of capital chasing crypto assets.

The true value of SPAC is not just to allow companies to bypass the lengthy IPO process for a quick listing. Its key lies in: companies can sell highly imaginative plans to investors even in the absence of actual business—such as "BTC holdings soaring to $1 billion by year-end." In this process, the founding team can even bring in giants like Galaxy to participate in PIPE (private investment in public equity) before the merger, locking in astonishing valuations ahead of time. The SEC's regulations appear to be followed on the surface, but in essence, they evade the sensitive identity of "investment funds."

More importantly, SPAC gives companies the opportunity to leverage very early on: first hoarding coins, then doubling down through equity or debt financing, continuously amplifying firepower with crypto assets as the underlying. This mechanism allows founders to completely bypass the traditional path of "building products first, then proving value," driving growth directly through narrative and financial tools. Compared to IPOs, SPAC offers them greater imaginative space and operational freedom.

The Combination of PIPE and Convertible Bonds is an important supplement to the entire script:

1. First, identify suitable shell companies or SPACs.
2. Collaborate with them to design a tailored crypto asset reserve strategy.
3. Work with investment banks to issue PIPE and convertible bonds, directly selling shares to institutions.
4. PIPEs often sell shares at a discount, leaving room for arbitrage for institutions.
5. Convertible bonds protect investors from downside risk while providing some upside returns, making them a preferred choice for stable capital.

Unlike Strategy's initial "anti-inflation reserve" narrative, today's PIPE players are more aggressive; they not only buy coins but also layer on staking, lending, and other operations to release on-paper profits more quickly. The secondary market's reaction is also extremely direct: whenever such transactions are disclosed, the company's stock price often skyrockets several times instantly. For Wall Street, this is a skilled financial packaging technique—translating "buying coins" into a complex financial structure and then extracting expensive premiums from investors through information asymmetry.

Of course, not all companies are fixated on major coins like BTC, ETH, and SOL. For smaller enterprises, those mid-tier tokens ranked in the top 50 are often more enticing targets. They are highly volatile, with astonishing potential returns, attracting waves of small treasury companies to gamble, but more often than not, they are fleeting, ultimately being washed out by the market.

What are the differences between ETH and SOL DAT compared to BTC?

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

BTC DAT Faces a Cold Wave, but mNAV Remains Stable

In August of this year, Strategy's stock price fell by a cumulative 16.8%, and the valuation premium the company enjoyed for years due to its Bitcoin holdings was almost completely eroded. This is not a simple stock price adjustment but more like a prelude to the gradual loss of luster of the Bitcoin corporate treasury story.

In fact, as emerging DAT strategies like Ethereum gradually gain a foothold, the industry status of Strategy, the "pioneer," is being diluted. More critically, there has been a turning point in financing methods. The company originally planned to finance Bitcoin purchases through preferred stock but only raised $47 million, far below external expectations. The funding gap forced it to restart common stock issuance, which undoubtedly broke the previously promised principle of "controlling dilution." In the context of capital markets, this means a loss of credibility.

This turning point is not an isolated case. Observing the capital flows of BTC, ETH, and SOL, it is not difficult to find that the market is moving towards diversification, and Bitcoin treasury companies are the first to feel the pressure of capital diversion. As the earliest group to attempt this model, they are also the first to enter a period of adjustment and pain. Currently, about one-third of publicly listed companies holding Bitcoin have stock prices that are even lower than the on-paper value of their Bitcoin. For small companies, this is particularly fatal: tight liquidity makes every equity financing exceptionally difficult, while heavy convertible bond interest and approaching repayment deadlines further compress survival space.

The companies that can truly succeed often share two common traits: first, a strong community consensus; second, the ability to continuously increase "Bitcoin holdings per share" and build financial engineering around this. Conversely, those lacking sustained strategic support are mostly eliminated by the market. For example, SOS Limited, after transitioning from crypto mining to commodity trading, not only faced difficulties in its main business but also struggled to sustain its Bitcoin strategy, ultimately falling far behind its peers. This shows that the "heavy Bitcoin" model is more favored by the market than "symbolic allocation."

Of course, these companies still face the impact of extreme volatility. When a company's net assets exceed its market value, it may brew a reversal opportunity, but for financially precarious companies, simply retaining a small amount of Bitcoin on paper is clearly insufficient to change the fate of bankruptcy. Moreover, when a company's strategy extends to tail tokens, the risks double. Such assets lack the hard asset attributes of Bitcoin and stable buying support, making them prone to collapse first during market adjustments.

ETH DAT Diversifies Returns, but mNAV is Fully Discounted

According to the latest Strategic ETH Reserve data, over 70 companies, public companies, or institutions worldwide have incorporated ETH into their strategic reserves (with single holdings exceeding 100 coins). The total holding has surpassed 4.7 million coins, valued at approximately $2 billion, accounting for 3.89% of Ethereum's total supply. Among them, about 14 companies have explicitly disclosed their "Ethereum treasury strategy," with total holdings close to 3 million ETH, valued at approximately $12.86 billion.

Unlike the "single holding" approach mainly adopted by Bitcoin treasury companies, those entering the ETH treasury track exhibit significant differentiation in asset utilization models. Their strategies can be roughly divided into four categories: one relies on third-party staking services for stable returns ("delegated"); another directly embeds into the network through self-operated nodes and liquid staking ("self-operated"); a more aggressive type combines lending, liquidity provision, and MEV optimization to maximize capital efficiency; and a portion is exploring advanced leverage strategies like circular lending to amplify asset returns.

Among the currently holding companies, the movements of the top five are particularly representative:

• BitMine became the largest corporate holder just two months after launching its ETH treasury strategy, with holdings rising to over 1.52 million coins, targeting 5% of ETH's total supply. Notably, Peter Thiel has acquired 9.1% of its shares. If staking is initiated subsequently, the profit potential is considerable.
• SharpLink Gaming, originally a sports betting company, officially positioned ETH as a core reserve asset in June and brought in Ethereum co-founder Joseph Lubin as chairman of the board. Its holdings are nearly fully staked, forming a stable passive income source.
• The Ether Machine, formed through a SPAC merger, plans to hold over $1.5 billion in ETH, with management publicly stating that they will focus on staking, re-staking, and DeFi operations, even mentioning attempts at circular lending on Aave.
• Bit Digital has completed its transformation from a traditional mining company to an Ethereum asset management and staking platform, with a clear strategic positioning.
• ETHZilla has shifted from biotechnology to the entertainment and gaming industry while developing ETH-related accumulation tools, with Peter Thiel's investment team also appearing behind it.

Overall, the logic of ETH treasury differs from that of Bitcoin. The core value of Bitcoin is more reflected in its positioning as a "reserve asset," while ETH's advantage lies in its native income channels. The current nominal yield rate for Ethereum staking is about 2.95%, with an inflation-adjusted real yield rate of 2.15%. If 30% of the existing corporate total holdings are staked, and ETH prices remain at $4,000, the corresponding annualized yield scale would be about $79 million. This figure reflects that ETH treasury companies can obtain relatively stable cash flow beyond price fluctuations.

On the operational level, companies mainly have two paths: one is to directly run validation nodes; the other is to leverage liquid staking protocols (such as Lido, Coinbase, RocketPool). The U.S. SEC has clarified that such protocols are not classified as securities, clearing compliance barriers for institutional participation and allowing them to additionally obtain liquidity tokens as derivative assets.

These derivative assets (like Lido's stETH) have high combinability in the DeFi market and can further be used as lending or liquidity mining tools. For example, in Aave v3, the ETH and stETH liquidity pool has exceeded 1.1 million ETH. As more corporate treasury funds flow in, the size of this pool is expected to continue expanding, significantly enhancing market liquidity while improving yield rates.

The core competitiveness of ETH DAT lies in the layered and scalable structure of its income. This gives it a stronger latecomer advantage compared to Bitcoin DAT.

SOL DAT Aims to Catch Up, but Scale is Still Small

An increasing number of public companies are starting to place SOL on their balance sheets. Currently, Solana's total market capitalization is approximately $107 billion, and data shows that public companies hold over 4 million SOL, valued at over $800 million. However, the stock prices of these companies are not impressive, possibly because the reserve market for Solana has yet to see a true leading strategy, and because SOL ETFs have not yet been approved.

However, a new wave of capital is rapidly joining. The SOL held by public companies currently only accounts for 0.69% of the circulating supply, while recently Pantera Capital committed to investing $1.25 billion, and Galaxy, Multicoin, and Jump jointly committed to investing $1 billion, totaling 3.5 times the current holdings of public companies.

More specifically, Galaxy, Multicoin, and Jump plan to acquire a public company to create a digital asset financial company focused on Solana. Meanwhile, Pantera, led by former Tiger Management executive Dan Morehead, also plans to raise $1.25 billion to acquire a NASDAQ-listed company and transform it into an investment company focused on SOL, tentatively named "Solana Co." Notably, Pantera and Galaxy previously bought a significant amount of SOL at low prices from the bankrupt FTX, making a substantial profit. In simple terms, their new moves can be understood as—having made enough money, they are ready to double down.

The rise of the DAT company model represents a new and advanced value capture method for these institutions. Through DAT, they can not only hold SOL while waiting for price increases but also earn steady profits through various DeFi protocols, achieving multiple asset appreciation.

From Bitcoin's performance over the past two years, it can be seen that when institutions begin to systematically accumulate a certain crypto asset, that asset often enters a relatively stable upward channel. The example of Ethereum has already demonstrated this. The differences between Solana and Ethereum DAT companies are also quite clear: institutions choose ETH largely because of its decentralization, while Solana is favored for its public chain attributes and user-oriented application potential.

In terms of the efficiency of DAT in absorbing trading supply, the $2.5 billion SOL DAT plan brought by Galaxy and Pantera is equivalent to a financing scale of $30 billion for ETH or $91 billion for BTC. The efficiency of SOL DAT can be higher than that of ETH for two reasons: first, circulating supply does not equal tradable volume; currently, 63.1% of Solana's tokens are staked, leaving very few available for trading; while ETH's staking rate is only 29.6%, with a larger tradable volume, making price movements more difficult. Second, in terms of relative capital impact, SOL's market capitalization is far lower than that of ETH and BTC, making the effect of investing $1 in SOL DAT far exceed the same investment in ETH and BTC.

Moreover, with the SOL ETF expected to be approved by the end of this year, this wave of buying behavior may have a more pronounced effect on prices.

Expectations for BNB and Other Tail Assets' DAT

BNB DAT

CEA Industries: Aiming for 1% of BNB's Total Supply

CEA Industries (stock code: BNC) recently announced that it has increased its BNB holdings to 388,888 coins, valued at approximately $330 million. The company plans to hold 1% of BNB's total supply, or about 10 million BNB, by the end of 2025. This move highlights its strategy of treating digital assets as a core part of its strategy, similar to MicroStrategy's approach in the Bitcoin space. Additionally, CEA Industries has partnered with 10X Capital to accept a $500 million private investment from YZi Labs, which includes $400 million in cash and $100 million in crypto assets, to further expand its BNB reserves.

Nano Labs: Gradually Increasing BNB Reserves

Nano Labs (NASDAQ code: NA) currently holds about 128,000 BNB, with an average acquisition cost of $713 per coin, totaling approximately $10.8 million. The company has increased its holdings by 8,000 BNB through OTC transactions, demonstrating its commitment to BNB as a long-term value reserve. This strategy may lay the groundwork for its further layout in the digital asset space.

Liminatus Pharma: Establishing "American BNB Strategy" Subsidiary

Liminatus Pharma (NASDAQ code: LIMN) plans to raise up to $500 million in phases through its newly established subsidiary "American BNB Strategy" to strategically invest in BNB over the next few years. This move marks a traditional biopharmaceutical company's active embrace of digital assets and exploration of the possibility of incorporating BNB into its asset allocation.

Windtree Therapeutics: Allocating $520 million in Financing to BNB Strategy

Windtree Therapeutics (NASDAQ code: WINT) announced plans to raise up to $520 million, with 99% of the funds allocated for purchasing BNB to enhance its digital asset treasury. The company has reached an agreement with Kraken to serve as the custodian for its BNB holdings. This move demonstrates the active transformation of traditional biotechnology companies in the digital asset space.

Hua Xing Capital: The First Hong Kong Listed Company to Directly Hold BNB

Hua Xing Capital signed a memorandum with YZi Labs in August 2025, planning to invest $100 million to purchase BNB, becoming the first Hong Kong listed company to directly hold BNB. Additionally, Hua Xing Capital plans to launch compliant BNB fund products and establish RWA based on BNB for stablecoins and on-chain applications.

B Strategy: Plans to Raise $1 Billion to Establish BNB Treasury Company

B Strategy plans to go public in the U.S. and establish a treasury company focused on BNB investment, targeting to raise $1 billion. The company has received strategic support from YZi Labs.

Amber International and Hash Global: Launching BNB Fund

Amber International (NASDAQ code: AMBR) has partnered with Hash Global to launch a BNB fund, aiming to use its $100 million crypto asset reserve for BNB investments. This fund serves as a blockchain-native income product, designed to provide stable income sources for institutional investors.

Ethena and SUI's DAT Layout

Ethena (ENA): Strategic Investments from StablecoinX and Mega Matrix

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. Additionally, Mega Matrix has submitted a $2 billion structured registration statement to the U.S. Securities and Exchange Commission (SEC) for reserving USDe and ENA.

SUI: Strategic Layout of Sui Group Holdings

Sui Group Holdings is the only publicly listed company supported by the Sui Foundation, holding approximately 102 million SUI tokens, valued at about $345 million. The company plans to continue raising capital to purchase more discounted locked SUI tokens to increase its SUI holdings per share, thereby creating value for shareholders.

Whether non-mainstream DAT can generate sufficient influence and even continuously produce a positive flywheel is crucial. The most important factor is not whether mNAV remains above 1 and in a premium state: mNAV may drop below 1, leading to discounts, but for these companies, selling crypto assets in a discounted state is an accelerated path to death.

The core direction for evaluating non-mainstream DAT should be financing ability and buying capacity:

The former represents the degree of optimism and confidence in the crypto asset, whether the company has good financing channels to buy in during discounted or downward cycles, which is the best endorsement for DAT companies. The positive effects generated by financing scale can promote mNAV to some extent. Observing the DAT processes of the aforementioned three crypto assets, both BNB and Ethena's DAT companies have very strong and broad financing capabilities, making them more likely to promote positive developments in coin and stock prices over the long term.

Secondly, the ability to continuously buy is also key; consistently and disciplinedly executing their investment strategies to prove their research and timing abilities to the market is the foundation for building a brand and winning premiums. Having enough ammunition to continue buying when discounts appear is the best injection of confidence to demonstrate to the market.

BNB, Ethena, and SUI have not yet experienced this stage, but when the FOMO of mainstream DAT subsides, whether tail asset DAT companies can survive, apart from the two aforementioned factors, may hinge on whether they can provide more asset play possibilities for crypto protocols: Wall Street only brings incremental capital; how to amplify leverage in the market is key to utilizing capital volume. How to maximize asset efficiency, innovate programmable liquidity, and capture multidimensional value, etc. Precise financial engineering and tangible returns will allow the best tail DAT companies to stand out.

Rational Perspective on DAT Flywheel

DAT is not some high-end financial innovation; it is essentially more like a regulatory arbitrage tool: in the current context where crypto asset regulations are not yet fully clarified, Wall Street or some public companies achieve rapid allocation of crypto assets through DAT structures. This wave of DAT frenzy superficially mimics the strategic layout of MicroStrategy, but the core driving force comes more from market FOMO during a period of still loose official regulatory channels. In other words, the prosperity of DAT carries obvious short-term speculative color, and its sustainability depends on the dual influence of market sentiment and regulatory policies.

In terms of the flywheel mechanism, DAT can amplify returns during bull markets: asset market values rise, mNAV premiums increase, and liquidity enhances, forming a positive feedback loop. However, once the market reverses, this mechanism can also amplify risks. When mNAV discounts or premiums disappear, some DAT companies may be forced to liquidate assets, triggering a chain selling pressure that amplifies short-term price volatility. The complex structure of DAT, while attracting institutional funds, also exacerbates information asymmetry, making it difficult for retail investors to fully understand risk exposure and the true value of assets.

From a valuation logic perspective, DAT may cause the market to return to a "story-driven" phase: prices in the short term rely more on market expectations, concept heat, and institutional participation. Hot money entering may push prices up, but this rise lacks underlying value support. The rise of Ethereum DAT is expected to boost on-chain staking, DeFi activity, and ecosystem participation, but its long-term impact on corporate profitability and the overall health of the ecosystem remains highly uncertain.

In summary, the DAT flywheel can create short-term returns and market attention during market booms, but investors need to rationally recognize its limitations: high leverage amplifies upside returns but also magnifies downside risks, while regulatory pressures, liquidity tightening, and mNAV discounts are key factors that could break this inflated structure at any time.

About Movemaker

Movemaker is the first official community organization authorized by the Aptos Foundation and jointly initiated by Ankaa and BlockBooster, focusing on promoting the construction and development of the Aptos ecosystem in the Chinese-speaking region. As the official representative of Aptos in the Chinese-speaking area, Movemaker is committed to building a diverse, open, and prosperous Aptos ecosystem by connecting developers, users, capital, and numerous ecological partners.

Disclaimer:

This article/blog is for reference only, representing the author's personal views and does not represent the position of Movemaker. This article does not intend to provide: (i) investment advice or recommendations; (ii) offers or solicitations to buy, sell, or hold digital assets; or (iii) financial, accounting, legal, or tax advice. Holding digital assets, including stablecoins and NFTs, carries high risks, significant price volatility, and may even become worthless. You should carefully consider whether trading or holding digital assets is suitable for you based on your financial situation. For specific issues, please consult your legal, tax, or investment advisor. The information provided in this article (including market data and statistics, if any) is for general reference only. Reasonable care has been taken in compiling this data and charts, but no responsibility is accepted for any factual errors or omissions expressed therein.