Complying with the GENIUS Act

September 15, 2025

Maredith Hannon

Director of Business Development, Digital Assets

Rick Harper

Chief Investment Officer, Fixed Income and Model Portfolios

One Small Step for our Money Market Fund, One Giant Step for Stablecoin Reserves

The GENIUS Act establishes a clear federal framework in the U.S. for how stablecoin issuers can invest their reserves
With portfolio adjustments to align with GENIUS Act reserve requirements, our digital money market mutual fund, the WisdomTree Government Money Market Digital Fund (WGTXX) (the “Fund”), already a 1940 Act government money market mutual fund under Rule 2a-7, can seamlessly align with the Act’s requirements
The adjustments to the Fund’s portfolio may result in a relatively small impact on yield, yet they unlock access to a much broader universe of investors, positioning WGTXX at the intersection of stablecoins and regulated money markets.

The passage of the GENIUS Act, more humbly known as the Guiding and Establishing National Innovation for US Stablecoins Act, was the game changer we anticipated it would be. The Act established a needed regulatory framework for stablecoin issuers and solidified the new frontier for digital asset investment. Within the Act, Congress set forth parameters for the investment of stablecoin reserves. The parameters fit comfortably inside of Rule 2a-7, which has long governed money market mutual funds, but place some additional restrictions on the maturity of individual security positions and eligible investments. WTGXX, WisdomTree’s 1940 Act–registered government money market fund, has already seen strong adoption as a reserve asset for stablecoin-native businesses. Last week, we announced our intention to make the investment tweaks needed to make the Fund GENIUS Act compliant by November 1, 2025, far ahead of January 2027 implementation start. By moving early, WisdomTree positions the Fund as a ready-made solution for stablecoin issuers, demonstrating leadership in regulatory preparedness. To signal this compliance, we will also change the official name to be the WisdomTree Treasury Money Market Digital Fund. The Fund will maintain the positive attributes and protections of the U.S. registered money market mutual fund structure, which other institutions and retail investors have gravitated towards, and we expect to continue.

What is Changing?

For stablecoin issuers, the GENIUS Act restricts the type and maturity of eligible securities to Treasury securities maturing in 93 days or less and overnight repurchase agreements backed by Treasury securities. By or around November 1, 2025, WGTXX will look to focus on this universe and exclude US government agency securities and Treasury securities maturing in more than 93 days, while adhering to all the parameters established for money market mutual funds. Currently, as of August 29, 2025, the Fund held 8.45% in agency securities and no Treasuries maturing in over 93 days (with 5.2% of the agencies maturing before November 1). Narrowing the focus to Treasuries also led us to strategically rebrand the Fund as the WisdomTree Treasury Money Market Digital Fund, which will become effective on or around November 1, 2025, a change that more closely aligns the Fund’s name with its investment policy and the requirements of the GENIUS Act.

While money market fund parameters enable investment in individual securities that mature in less than 397 days and accommodate a wider selection of investments, they also include parameters that limit overall fund maturity (to 60 days), constrain risk, and have minimum liquidity requirements to ensure that funds can maintain a stable net asset value. These checks and balances mitigate the tradeoffs in complying with the GENIUS Act.

We don’t have a crystal ball, but we do not believe that the yield impact will be material in either direction. However, market conditions can change, and with the portfolio changes, the Fund’s yield may be lower relative to government money market funds investing in a wider universe of investments.

* While not explicitly stated in the GENIUS Act, a money market mutual fund complying with the Genius Act would also need to adhere to the maturity restrictions and liquidity constraints to retain its standing as a money market mutual fund.

**What is Not Changing:**

The Fund’s investment objective will not change, whereby the Fund will continue to seek to provide investors with a high level of current income consistent with preservation of capital and liquidity and the maintenance of a stable $1.00 net asset value (NAV) per share. The Fund will continue to operate as a money market fund and enjoy all the privileges and safeguards that Rule 2a-7 offers, including strict limits on portfolio maturity, high credit quality standards, built-in diversification requirements, and robust liquidity thresholds to ensure daily access to cash. Rule 2a-7 funds also provide enhanced protections through board oversight of fund operations and stress testing, as well as the bankruptcy-remote structure of the Fund, which insulates investor assets from the sponsor’s balance sheet. Collectively, these protections serve as a comprehensive risk management framework, mitigating credit, liquidity, and market risks to safeguard investors’ capital and preserve the stability of the Fund’s $1.00 NAV. Lastly, the Fund’s management fee is not changing and its ticker symbol of WTGXX will remain the same.

The importance of the GENIUS Act lies in the potential to make stablecoins a mainstream payment tool, unlocking access to the full US banking and payments infrastructure. The reserve requirements put in place by the Act provide a foundation that will underpin and facilitate the acceptance of stablecoins and lays the groundwork for broader trust, adoption and growth. With the portfolio adjustments discussed, WGTXX can solidify its position as a reserve asset for stablecoin issuers that meets the Act’s requirements, while continuing to provide an attractive risk-return profile for money market investors. In short, one small step for WTGXX, one giant step for stablecoin reserves.

Disclosures:

Investors should carefully consider the investment objectives, risks, charges, and expenses of the Funds before investing. For a prospectus containing this and other important information, call 866.909.WISE (9473) or click here to view or download the documents. Read the prospectus carefully before investing.

You could lose money by investing in the Money Market Fund. Although the Fund seeks to preserve the value of your investment at $1.00 per share, it cannot guarantee it will do so. An investment in the Fund is not a bank account and is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. The Fund’s adviser is not required to reimburse the Fund for losses, and you should not expect that the adviser will provide financial support to the Fund at any time, including during periods of market stress.

You cannot invest directly in an index.

There are risks associated with investing, including possible loss of principal. Because the Funds are new, they have limited performance history. Blockchain technology is a relatively new and untested technology, with little regulation. Potential risks include vulnerability to fraud, theft, or inaccessibility, and future regulatory developments effect its viability. Funds focusing investments on certain sectors increases its vulnerability to any single economic or regulatory development, which may result in greater share price volatility. U.S. Treasury obligations may provide relatively lower returns than those of other securities. Changes to the financial condition or credit rating of the U.S. government may cause the value to decline. TIPS can provide a hedge against inflation, as the inflation adjustment feature helps preserve the purchasing power of the investment. Because of this inflation adjustment feature, inflation protected bonds typically have lower yields than conventional fixed rate bonds and will likely decline in price during periods of deflation, which could result in losses. Securities with floating rates can be less sensitive to interest rate changes than securities with fixed interest rates, but may decline in value and negatively impact a Fund’s NAV, particularly if changes in prevailing interest rates are more frequent or sudden than the rate changes for floating rates notes, which can only occur periodically. Fixed income securities are subject to interest rate, credit, inflation, and reinvestment risks. Generally, as interest rates rise, the value of fixed-income securities falls. Cybersecurity attacks affecting a Fund’s third-party service providers, App, blockchain network, or the issuers of securities in which the Fund invests may subject the Fund to many of the same risks associated with direct cybersecurity breaches.

WisdomTree Digital Funds are distributed by WisdomTree Securities, Inc., Member FINRA.

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The WisdomTree Prime digital wallet and digital asset services are offered through WisdomTree Digital Movement, Inc., a federally registered money services business, state-licensed money transmitter and financial technology company (NMLS ID: 2372500) or WisdomTree Digital Trust Company, LLC, in select U.S. jurisdictions and may be limited where prohibited by law.

WisdomTree Digital Trust Company, LLC is chartered as a limited purpose trust company by the New York State Department of Financial Services to engage in virtual currency business.

This material contains the opinions of the author as of the date shown above, which are subject to change and do not represent the views of WisdomTree or any of its affiliates unless expressly stated otherwise. The material represents an assessment of the market environment at a specific time and is not intended to be a forecast of future events or a guarantee of future results. No warranty of accuracy or reliability is given and no responsibility arising in any way for errors or omissions is accepted by WisdomTree or its affiliates. There is also no guarantee that any strategies discussed will work under all market conditions. The material is intended for informational purposes only and does not constitute investment advice, investment recommendations or an offer or solicitation to purchase or sell any products or services, including digital assets or securities. The user of this material assumes the entire risk of any use made of or reliance upon the information provided herein. Neither WisdomTree or its affiliates provide tax or legal advice. No part of this material may be reproduced in any form or referred to in any other publication, without express written permission.

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About the contributors

Maredith Hannon

Director of Business Development, Digital Assets

Maredith Hannon joined WisdomTree in May 2022 as Director of Business Development for Digital Assets. In this role, she is responsible for leading business development and partnerships for WisdomTree’s digital assets division, including WisdomTree Prime.

Prior to joining WisdomTree, Maredith was an Executive Director at Morgan Stanley, Head of Business Development and Strategy for the Outsourced Chief Investment Office (OCIO). In this role, she was responsible for sales and operations across business development, marketing, strategic initiatives, and business management. OCIO’s client base included institutional clients, including family offices, ultra-high net worth clients, defined contribution and defined benefit plans, nonprofits, and corporations, both domestic and international. Maredith began her career at Bank of America Merrill Lynch where she worked across product, sales, and strategy roles before becoming Director, Head of Sales Performance and Strategy for their Workplace Financial Solutions business, which focused on delivering wealth management solutions to institutional clients and their employees.

Maredith graduated cum laude with a Bachelor of Arts degree from Georgetown University.

Rick Harper

Chief Investment Officer, Fixed Income and Model Portfolios

Rick Harper serves as the Chief Investment Officer, Fixed Income and Model Portfolios at WisdomTree Asset Management, where he oversees the firm’s suite of fixed income and currency exchange-traded funds. He is also a voting member of the WisdomTree Model Portfolio Investment Committee and takes a leading role in the management and oversight of the fixed income model allocations. He plays an active role in risk management and oversight within the firm.

Rick has over 29 years investment experience in strategy and portfolio management positions at prominent investment firms. Prior to joining WisdomTree in 2007, Rick held senior level strategist roles with RBC Dain Rauscher, Bank One Capital Markets, ETF Advisors, and Nuveen Investments. At ETF Advisors, he was the portfolio manager and developer of some of the first fixed income exchange-traded funds. His research has been featured in leading periodicals including the Journal of Portfolio Management and the Journal of Indexes. He graduated from Emory University and earned his MBA at Indiana University.

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