Digital Fund Comparison: WTGXX vs. CUSHY

Tokenized U.S. Treasury products now account for over $15 billion in onchain value, and sit alongside a growing set of funds offering yield through various strategies. Many of them look similar from the outside, and are mostly evaluated based on the yield they advertise.

That said, a top-line yield figure tells you very little about how a fund actually works. A fund arrives at its yield only after it has decided how to register, who it will admit as an investor, and what it can hold. Those decisions differ sharply from one product to the next, which is why two funds can post very different rates while serving entirely different purposes.

Coinbase's CUSHY and WisdomTree's Treasury Money Market Digital Fund (WTGXX) are often grouped together on that basis, since both offer onchain yield. But they are structurally different. CUSHY is a private credit fund managed by Coinbase Asset Management, and WisdomTree’s WTGXX holds short-term U.S. Treasury securities. Let’s unpack the core differences between these two funds, starting with how they are registered and the resulting investor implications.

Fund Structure and Regulation

A fund's regulatory structure determines its investor eligibility, its custody arrangements, and the legal protections attached to its shares. CUSHY and WTGXX register under different regimes, and this single distinction accounts for many of the product differences that follow.

CUSHY is a private fund offered under Regulation D, domiciled in the Cayman Islands and managed by Coinbase Asset Management. It launched in 2026 on Superstate's tokenization platform and relies on private-placement exemptions rather than registration as a public fund.

WTGXX is registered under the Investment Company Act of 1940, the federal framework that governs traditional mutual funds and money market funds. It operates under Rule 2a-7, the same rule that applies to conventional money market funds, and sits within the U.S.-domiciled WisdomTree Digital Trust. In February 2026 it received SEC exemptive relief allowing its tokenized shares to trade and settle 24/7, which is a regulatory milestone most other fund issuers have not met.

The two structures carry different protections. A '40 Act fund brings independent board oversight and bankruptcy-remote custody by design. A Reg D private fund operates under the lighter requirements available to funds that restrict who can invest.

Investor Eligibility

A fund's minimum investment says a lot about who it was built for. CUSHY and WTGXX sit at opposite ends of the accessibility spectrum, with one reaching institutions and accredited investors while the other is designed for everyone, from institutional to retail investors.

CUSHY is open to accredited investors and qualified purchasers, including both U.S. and certain eligible non-U.S. investors, with a minimum initial investment of $100,000. Access runs through Coinbase Prime, the firm's institutional platform.

WTGXX is available to both retail and institutional investors. Retail investors can access it through the WisdomTree Prime app at a $1 minimum, and institutions can access it through WisdomTree Connect. WisdomTree Prime is available to investors in the United States.

Yield Source and Rate

A yield figure carries different weight depending on whether it reflects a realized track record or a forward target. CUSHY and WTGXX differ both in terms of the assets that generate each fund’s return and in how much history backs each number.

CUSHY targets a yield in the range of SOFR plus 400 to 700 basis points. It generates that return through private credit strategies, including direct lending and crypto-collateralized loans, with origination drawn in part from Apollo Global Management. That number is still a target rather than a realized return, since the fund only launched in 2026. As a result, the spread over SOFR is what compensates investors for the credit and illiquidity risk that private lending carries.

WTGXX has held a 7-day yield near 3.5% through July 31st, 2026. Its yield comes from short-term U.S. Treasury securities and Treasury-backed repurchase agreements, which are holdings that move with short-term interest rates rather than with credit conditions. Rule 2a-7 limits what the fund can hold, which keeps its return profile deliberately narrow and tightly aligned with prevailing government rates.

Fee Structure

A fund's fee structure is typically influenced by the work it does to earn its return, so fees tend to differ by strategy rather than by fund provider. As a result, an actively managed credit fund and a money market fund charge along different lines.

CUSHY carries a management fee of 1.25% on its standard share class and 0.75% on its tokenized share class, along with a 10% performance fee. WTGXX carries an expense ratio of 0.25% and no performance fee.

Those arrangements follow directly from what each fund does. Actively managed private credit involves sourcing, underwriting, and monitoring individual loans, work that commonly commands a management fee plus a share of performance. A money market fund holds a standardized, highly liquid portfolio and typically charges an expense ratio alone.

Custody and Track Record

Structure and yield describe what a fund is, while operating history and scale reflect the degree to which it demonstrated that model in the market. A fund that has run through multiple rate environments since 2023 is in a very different position than one still deploying its initial assets, regardless of how sound either structure may seem.

WTGXX has operated since January 2023 and held $876 million in assets under management as of April 30, 2026. Custody runs through Bank of New York Mellon, and the fund is live across eight leading blockchains.

CUSHY launched in 2026 and held roughly $25 million in assets shortly after funding, with custody and administration handled through Coinbase Prime and Northern Trust. Its tokenized shares went live first on Solana, with availability designed for Ethereum and Base as well.

These figures reflect how long each fund has been operating and how far each has progressed in its rollout. They speak to stage and scale, which stand apart from how either fund is structured or how it generates its yield.

Different Funds for Different Investors

CUSHY and WTGXX are not two versions of the same product. One is a private credit fund available to qualified purchasers seeking exposure to structured lending. The other is a registered Treasury money market fund available to retail and institutional investors seeking exposure to short-term government debt.

The yield each fund advertises flows from those choices, from what it can hold and whom it can serve. For investors who are able to access both funds, the real question comes down to what you are actually underwriting to earn that yield, and how well each fund’s track record holds up. CUSHY pays investors to take on private credit risk, and WTGXX pays them to hold short-term government debt. Which fund works best within your portfolio comes down to your investor profile and overarching strategy.