# Ketju research: Coinbase USD Stablecoin Yield Fund (CUSHY)

- URL: https://riadefi.com/rejections/coinbase-stablecoin-yield/
- Research assessment: adverse
- Client selection: not considered
- Exposure: tokenized RWA
- Reviewed: 2026-09-24
- Next review: 2026-12-24

## Research summary

CUSHY is a share of Coinbase Tokenized Stablecoin Yield Feeder Fund Ltd, a Cayman company that Coinbase Asset Management runs to lend stablecoins and buy credit. It targets SOFR plus 4 to 7 percentage points and showed a 30-day yield of 7.54% on Superstate’s page. Superstate is transfer agent and issues the token on Solana and Base. The Form D, filed 23 June 2026, reports $25 million sold to two investors, and two Solana wallets hold 240,000 of the 250,000 tokens.

The Form D claims Rule 506(c) and the Investment Company Act section 3(c)(7) exclusion, so only qualified purchasers may buy. The minimum is $100,000, which the manager may raise, lower, or waive. Subscriptions are monthly and redemptions quarterly: a request made in one calendar quarter is paid on a dealing day in the next.

The assessment is adverse. Model clients are not qualified purchasers. For one who is, CUSHY pays a spread for lending to crypto borrowers, charges 0.75% plus 10% of returns, returns money once a quarter, and has two holders; the token adds allowlisted transfers, not an earlier exit.

## Observable review triggers

- Coinbase Asset Management or Superstate publishes the offering memorandum and it changes the investor class, fees, or redemption terms
- The fund opens to accredited investors under section 3(c)(1)
- The fund gates or delays a quarterly redemption, or a borrower default cuts NAV
- The Solana mint authority or the Base owner key moves to a multisig with a delay

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Published by Ketju Research (https://ketjuresearch.com). Educational analysis only; not legal, tax, compliance, or investment advice.
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