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The U.S. Securities and Exchange Commission on Feb. 23 issued an exemptive order permitting intraday dealer trading in shares of WisdomTree’s tokenized government money market fund, granting relief from forward-pricing requirements under the Investment Company Act. The SEC order (Release No. 35968) allows “Covered Dealers” with dealer agreements to buy and sell the fund’s shares to investors at a fixed $1.00 per share rather than the next-calculated NAV. Reuters reported the decision as enabling intraday trading of tokenized shares of WisdomTree’s money market fund and cited SEC staff comments framing the relief as maintaining regulated money market fund protections while changing how transactions can occur during the day.
The SEC order covers WisdomTree Digital Trust and affiliated entities, including WisdomTree Securities, Inc., which is identified in the application materials as an “Affiliated Dealer,” alongside other Covered Dealers that may participate under the same framework. Under the structure described to the SEC, dealer-facilitated trades occur on a principal basis with the dealer (at $1.00 per share, plus or minus dealer compensation where applicable), while dealer purchases and redemptions with the fund itself remain in cash at the fund’s next-calculated NAV.
The fund referenced in the SEC order is the WisdomTree Government Money Market Digital Fund; WisdomTree’s current materials for WTGXX state the fund was renamed the WisdomTree Treasury Money Market Digital Fund as of Nov. 1, 2025, and describe an “integrated recordkeeping system” in which digital representations of shares are tokenized on supported blockchains while the fund does not invest in cryptocurrencies. The SEC filing explains that the fund is expected to use blockchain technology for its share record and to permit peer-to-peer transfers between permissioned investors as described in its prospectus, with the affiliated transfer agent identified as part of the applicant group.
In regulatory terms, the relief is non-trivial because Investment Company Act Section 22(d) and Rule 22c-1 generally require mutual fund transactions to be priced at the next-computed NAV after an order is received (“forward pricing”), and the SEC had to use its exemptive authority under Section 6(c) to permit fixed-price dealer transactions in this setting. The SEC’s order is conditioned and narrow: the application limits the approach to a government money market fund subject to Rule 2a-7 whose shares are not exchange-listed, and it builds in guardrails tied to the fund’s “shadow” NAV—if the shadow NAV deviates by 0.25% or more from amortized-cost NAV, dealer trading must be suspended or revert to next-NAV pricing under the conditions described.
The practical impact is primarily on broker-dealers and the distribution plumbing around tokenized funds, because Covered Dealers can intermediate intraday buy/sell activity at a stable $1.00 share price while the fund itself continues to transact at NAV at its regular calculation points. For investors and tokenization platforms that connect to regulated fund shares, the change alters how intraday liquidity can be provided—through dealer inventory and principal trades—within the constraints and disclosures spelled out in the SEC application and order.
