TLDR:
- Strategy emphasizes DATs are operating companies, not passive investment funds.
- MSCI’s 50% digital-asset rule is arbitrary and could destabilize index inclusion.
- The proposal risks inconsistent treatment due to asset volatility and accounting differences.
- Strategy recommends a neutral, deliberative approach aligned with market evolution.
Strategy Inc., formerly MicroStrategy, has formally responded to MSCI’s consultation on digital-asset treasury companies (DATs), urging a neutral and consistent indexing approach.
The company argues that MSCI’s proposed rule, which would exclude firms holding 50% or more of their balance sheets in digital assets, mischaracterizes DATs and could create unnecessary market disruption.
Strategy emphasizes that its operations actively use Bitcoin to generate returns, making it an operating company rather than an investment fund. The firm stresses that “index standards should be neutral, consistent, and reflective of global market evolution,” encouraging MSCI to consider a fair framework.
In its response, Strategy highlights that the company’s treasury operations offer Bitcoin-backed digital credit instruments and other securities designed to provide investors with strategic exposure.
It notes that this active management distinguishes DATs from funds that passively hold digital assets.
Strategy states that the 50% threshold proposed by MSCI is arbitrary and discriminatory, and could lead to index instability due to asset price volatility and variations in accounting standards.
DATs Call for Consistent Treatment and Clear Standards
Strategy contends that MSCI’s proposal creates challenges by treating digital assets differently from other concentrated asset holdings.
The company explains that “a digital-asset-specific 50% threshold is discriminatory, arbitrary, and unworkable,” pointing out that industries such as real estate, oil, or timber often maintain highly concentrated balance sheets without facing similar exclusions.
The company also emphasizes operational flexibility as a key characteristic of DATs. Strategy notes that it actively deploys Bitcoin in financial instruments, similar to long-standing practices in banking and insurance, allowing the firm to adapt strategies as technologies evolve.
The company argues that this operational approach differentiates it from passive funds and provides value to shareholders.
Strategy warns that applying the proposed rule could force MSCI into constant auditing under inconsistent standards. “Asset price swings, accounting changes, and jurisdictional differences would lead to arbitrary and inconsistent index inclusion,” the company states.
It adds that the approach could create confusion for institutional investors and diminish the reliability of MSCI indices.
The company shared on its corporate channel that “whichever direction MSCI takes, the decision should support market neutrality and fairness,” reinforcing the call for consistent evaluation across industries and asset types.
Aligning Index Policy With Market Evolution and U.S. Innovation Goals
Strategy emphasizes that MSCI’s role as a standard-setting organization is to reflect market evolution without injecting policy judgment.
The company notes that the proposed digital-asset-specific threshold could make MSCI an arbiter of investment decisions, which is outside its traditional function.
Additionally, Strategy links the issue to broader U.S. innovation policies. “Digital assets represent foundational technologies with potential to drive global financial growth,” the company explains, warning that excluding DATs at this stage could discourage investment in an emerging sector.
Strategy urges MSCI to allow the market to mature and extend public consultation before making any classification changes.
The company references MSCI’s method when forming the Communication Services sector, which involved years of observation and stakeholder feedback.
Strategy concludes that a deliberative and neutral approach is preferable, stating, “A rushed exclusion of DATs could have adverse consequences based on insufficient information and mistaken assumptions about market evolution.”
This recommendation frames Strategy’s call for balanced treatment in MSCI indices while highlighting the importance of operational business models, consistent standards, and alignment with global digital-asset growth.
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