"Strategy argued that the proposed threshold is "misguided" and would have "profoundly harmful consequences" for both investors and the broader digital asset industry. Founded in 1989, the company operates as a corporate treasury and capital markets business with significant Bitcoin holdings, offering investors a range of equity and fixed-income securities backed by its digital assets. According to the company, its model is fundamentally different from a passive investment fund."
"The company emphasized that "DATs are operating companies, not investment funds," noting that its operational flexibility allows it to adapt its business model as the technology evolves. Strategy calls MSCI's logic "arbitrary, and unworkable." Strategy criticized MSCI's proposal for introducing a digital-asset-specific 50% threshold, calling it "discriminatory, arbitrary, and unworkable." The company highlighted that many traditional businesses - including oil companies, timber operators, REITs, and media firms - also maintain concentrated holdings in single asset types but are not treated as investment funds."
Strategy, the world's largest Bitcoin treasury company, formally responded to MSCI's consultation urging the index provider not to exclude companies whose digital asset holdings exceed 50%. The company argued that the proposed 50% threshold is misguided and would have profoundly harmful consequences for investors and the digital asset industry. Strategy described itself as a corporate treasury and capital markets business that actively uses Bitcoin reserves to generate returns through equity and fixed‑income securities and novel instruments akin to bank and insurance products. The company stated that DATs are operating companies, not investment funds, and warned the threshold would cause index instability and inject policy into index construction.
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