# Benchmark Statement — ETP Foundry Canton Series

**Version 0.2 DRAFT · 29 September 2026 · ETP Foundry (formerly CrossDesk)**

> **Governing text.** [ETP Foundry Methodology v1.0](/documents/methodology-v1.0.md) (28 September
> 2026) is the sole governing methodology. This statement summarises it for a licensee's risk and
> compliance team; where the two differ, Methodology v1.0 governs. It supersedes
> [version 0.1](/documents/benchmark-statement-v0.1.md) (22 September 2026), which stays published,
> marked superseded.

> **No value described here has been published for commercial use.** Every value published today
> is tier 0: computed by the desk, attested by no independent party. This statement becomes
> effective on the date of the first value published above tier 0, and not before.

A benchmark statement is what a licensee's risk and compliance team reads instead of the
methodology: what the number measures, what it does *not* measure, who should use it, when
it publishes, and what happens if it stops. It follows the structure UK/EU BMR requires of
authorised administrators (Art. 27) and the shape used by CF Benchmarks. Following that
structure is not a claim to be regulated (§2).

---

## 1. Version history

| Version | Date | Changes |
|---|---|---|
| 0.1 | 22 Sep 2026 | Initial draft. Not effective. Superseded by 0.2. |
| 0.2 | 29 Sep 2026 | Conformed to Methodology v1.0: two venues are a condition of any value above tier 0 (one venue: tier 0, published); crypto strike 16:00 London (adopted 28 Sep 2026); oversight per Methodology §9.1; no exchange-derived value published; regulatory wording corrected. Not effective. |

## 2. Introduction

**Administrator:** ETP Foundry (formerly CrossDesk), operated by Lucilla, Inc., Toronto, Ontario, Canada.
**Contact:** hello@etpfoundry.com · security reports: security@etpfoundry.com · etpfoundry.com

**Regulatory status — stated plainly:** ETP Foundry is **not an authorised or registered
benchmark administrator in any jurisdiction**, and does not claim that status. It is not
supervised by the FCA, ESMA or any other authority. Whether a given use of a value brings it
within a regulatory definition of a benchmark depends on the use and the jurisdiction; this
statement does not assert a conclusion either way. See Methodology v1.0 §12 and
[Regulatory](/regulatory).

**Series covered:** the ETP Foundry Canton Series — fixings for tokenised assets recorded on
the Canton Network, and for baskets of them.

## 3. Benchmark description and aims

**What these benchmarks seek to measure:** the price at which a tokenised asset, or a
defined basket of tokenised assets, could be exchanged at a defined moment — determined from
the signed window submissions of the venues where it trades, checked by a lender from the risk
side, and gated by the issuer on peg integrity (Methodology v1.0 §3–§6).

**The underlying economic reality:** for a single wrapped asset (e.g. cBTC), it is the
exchange of that token for its quote asset on venues where it actually trades. For a basket,
it is the cost of assembling the constituent tokens in their stated weights. **We price the
token, not the asset it wraps or represents.** The wrapper's reserve condition enters through
the issuer's peg-integrity gate (Methodology §4.3, §6.2), never silently.

**The gap these exist to fill:** a basket of tokenised assets has no observable price even
when every constituent does, and a tokenised asset whose home market is closed has no
reference price at all for most of each week.

## 4. Methodology summary

Full rules: [Methodology v1.0](/documents/methodology-v1.0.md). In brief:

- **Inputs are data, in a published hierarchy** (§3): (a) venue transactions, (b) executable
  quotes, (c) reference × par factor, (d) the prior value carried forward, flagged.
- **Venues** submit, once a day, signed aggregates of their own trades in the 60-minute window
  ending at the strike. The fixing is the **volume-weighted median** of the eligible venue VWAPs,
  after an outlier rule, a share floor and a weight cap (§5.2, §5.3).
- **The lender** submits its own mark from its own risk system: a **basis check** (risk-side
  challenge) on the value, not an independent price (§4.2).
- **The issuer** gates the value on peg integrity: reserves at least equal supply, redemptions
  open, a fresh snapshot (§4.3, §6.2).
- **K of N** committee seats sign; the administrator computes and never attests (§4.6, §6.1).
- **Two independent venues are a condition of any value above tier 0.** With one venue the value
  is computed, flagged single source and **published at tier 0** (§5.3, §6.4). The pilot may run
  with one venue on that basis.
- **Level (c) and the tier 3 fallback require a licensed reference.** None is licensed today, so
  level (c) is unavailable for publication and the fallback proceeds to tier 4 (the prior
  committee value, flagged) or tier 5 (`NO FIXING`) (§3.1, §6.2). No value derived from
  exchange data (Coinbase, Kraken, Bitstamp or any other) is published; where no committee value
  exists, the public series shows "not published, awaiting a licensed source".
- **Every value carries its tier and input level** (§6.4). No value is published above tier 0
  until all four §6.4 conditions hold: a constituted independent oversight function that has
  approved the methodology (countersigned by its members from their own accounts); at least K
  signatures by third parties with their own keys (L2 or above); no seat counted toward K
  operated by the administrator or its affiliates, whatever its trust level; and the venue
  conditions, including two independent operators.

## 5. General disclosure — limitations

**This section is the honest one and is not to be softened.**

1. **No track record.** As of this version, no value has been published above tier 0. A
   benchmark's reliability is demonstrated by an unbroken history, and ours does not yet exist.
2. **Thin markets.** Canton-native tokenised assets trade on young venues with modest
   volume. A benchmark can be no more robust than the market it observes.
3. **Wrapper risk.** For wrapped assets, the value depends on a reserve we do not hold and
   an attestation we do not produce. A reserve shortfall is a price event we can report but
   not prevent.
4. **Committee dependence.** A fixing requires K signatures. If K is not reached, the
   fallback is tier 4 (the prior value, flagged and aged) or tier 5, a gap published as a gap.
5. **Concentration.** With few venues, a single venue may represent a large share of
   observed volume. With three or more venues, no venue carries more than 50% of the weight;
   **with exactly two, the larger venue's VWAP is the value**, and only if it lies inside the
   other venue's reported range (Methodology §5.3, §9.2).
6. **Not a valuation of the underlying.** A cBTC fixing is not a bitcoin price. A tokenised
   equity fixing is not the share price. Users who need the underlying should use a
   benchmark for the underlying.
7. **Not suitable, yet, to underlie a regulated financial product.** See
   [suitability-analysis-v0.1.md](/documents/suitability-analysis-v0.1.md).

## 6. Usage of the benchmark

| Type | May be used for | May **not** be used for |
|---|---|---|
| Live indicative value (unsigned, tier 0) | information only | anything that settles, margins or liquidates |
| `OFFHOURS` signed fixing (Methodology §3A; specified, not built) | margin, haircuts, health factors, collateral monitoring, once attested | **NAV, creation/redemption, audited records**; and, while labelled `pilot — not attested`, liquidation |
| `OFFICIAL` fixing | NAV, creation/redemption, reporting, contract settlement, **at tier 1 or 2 only** | — |

**Prohibited representation [FIXED]:** no licensee may present an off-hours or indicative value
as a NAV, or a tier 0 value as attested. This is a term of the licence.

**Licence classes:** use/reference, redistribution, display. Reading the value through an
oracle or data vendor does not substitute for a use licence.

## 7. Publication timings

Per Methodology v1.0 §1 and §3A.0:
- **OFFICIAL, crypto (CBTC, cETH, Canton Coin):** **16:00 Europe/London** every day, weekends
  included (adopted 28 September 2026). The observation window is the 60 minutes ending at the
  strike (15:00–16:00 London), as for the CME CF Bitcoin Reference Rate.
- **OFFICIAL, equities and any basket with an equity leg:** the home-market close, 16:00
  America/New_York on NYSE trading days.
- **Off-hours signed fixings** (specified, not built): 00:00, 08:00 and 16:00 **UTC** every day.
  In winter the 16:00 UTC slot coincides with the London strike and only the OFFICIAL is
  published; during British Summer Time it falls one hour after it.

Times are declared once and moved only as a material methodology change (§8). Values are
published to the ledger with their full fixing record, and on etpfoundry.com.

## 8. Changes to, and cessation of, the benchmarks

**Changes (Methodology §9.6):** a material change needs a public consultation of at least
30 days, then at least 30 days' notice before it takes effect. Non-material clarifications take
effect on publication. Every value is read under the version in force at its strike. **No
change is ever retroactive.**

**Cessation (§9.7):** at least 60 calendar days' notice, enforced on-ledger (`CessationNotice`),
naming the final strike and any successor. The methodology and history may be transferred to a
successor administrator.

## 9. Oversight

**Oversight function (Methodology §9.1): not constituted.** The target is at least three
members, a majority independent of the administrator and of every seat holder, with an
independent chair. **The committee of seats is not an oversight function**: its members hold
positions, which is why their role is limited to supplying and checking data. Until an
independent oversight function exists, the administrator performs the reviews, publishes them,
and says that it does so; and no value is published above tier 0 (§6.4 condition 1).

**Conflicts:** any interest of the administrator or a signer in a priced asset is disclosed
in the conflicts register and, where material, disqualifies that party from signing. The
administrator's fee may be linked to assets referencing its values; the mitigation is §6.4
(independent oversight, K signatures by third parties, no administrator seats), not the
administrator's own restraint. See the [conflicts policy](/documents/conflicts-policy-v0.2.md).

**Complaints (§9.5):** anyone may complain in writing to committee@etpfoundry.com about a
fixing, a submission or the methodology.

## 10. Updates to this statement

Reviewed at least annually and on any material methodology change. Superseded versions
remain published, marked superseded.