F/m Investments has filed for Securities and Exchange Commission (SEC) exemptive relief to record shares of its US Treasury 3-Month Bill ETF (TBIL) on a blockchain.
The 21 Jan filing is a significant move to bridge the $6.3bn fund into the digital settlement era. If approved, the $27tn US Treasury market will have its first live test of a 1940 Act-compliant ETF that functions onchain without sacrificing regulatory oversight.
This filing represents the next logical step in the institutional shift Sandmark has tracked since the launch of the BlackRock BUIDL fund last year. While previous products were "born digital," F/m is attempting to retrofit a massive, existing ETF wrapper.
This allows institutions to keep their current holdings while gaining the 24/7 settlement and collateral flexibility of the blockchain.
Defining the CUSIP bridge
The core of the F/m proposal hinges on the use of a single CUSIP (Committee on Uniform Securities Identification Procedures) identifier for both traditional and tokenized shares.
A CUSIP is a unique nine-character alphanumeric code that acts as the "social security number" for a security, ensuring it can be tracked, cleared and settled across the global financial system.
By maintaining the same CUSIP, F/m ensures that a tokenized share of TBIL is legally and operationally identical to a standard share. This avoids the "liquidity fragmentation" that occurs when digital versions of assets are issued under new, separate identifiers.
For a fund manager, this means the move to onchain settlement does not require a change in tax reporting, accounting, or internal compliance protocols. According to Bloomberg, this "same-wrapper" approach is designed to satisfy regulators who have previously been wary of pure-play crypto products.
Institutional plumbing over retail speculation
For the SEC, the F/m filing is a cleaner test case than previous crypto-native applications.
It focuses entirely on "plumbing" - the record-keeping and settlement of the asset - rather than the asset itself. As Sandmark noted in our 2026 Macro Outlook, the goal for Wall Street is to move the US dollar's foundational assets into a programmable environment.
Alexander Morris, CEO of F/m Investments, said in an announcement that the industry must decide whether this transition occurs within the 85-year-old regulatory framework or outside it.
By keeping TBIL under the 1940 Act, F/m is betting that the SEC will favor innovation that stays inside the "gold standard" of US investor protection.
