HODL: the clearest cautionary tale about fee waivers in the whole category

What HODL is

HODL is VanEck's spot Bitcoin ETF, listed on Cboe BZX since 11 January 2024. Like every fund on the US spot Bitcoin ETF list, it is a grantor trust registered under the Securities Act of 1933 rather than an investment company under the 1940 Act, it holds actual bitcoin with a qualified custodian rather than futures, and it deducts its sponsor fee in bitcoin rather than billing you in cash. The ticker is a joke that has outlived its own explanation, and VanEck deserves some credit for committing to it.

On size it sits in the second tier. Third-party data put HODL at roughly $1.1bn on 30 July 2026, which is real money and also about 1.8% of what IBIT holds. VanEck does not publish a coin count the way BlackRock, Fidelity and Grayscale do, so the dollar figure is the only handle available and it is an aggregator figure rather than an issuer one. We flag that because a fund's own filings and a data vendor's snapshot are not the same class of evidence, and this page tries to keep the distinction visible.

What makes HODL worth a page of its own is not its size or its structure, both of which are unremarkable. It is what happened to its fee on the last day of July 2026.

The waiver that expired on schedule

VanEck's offer was genuinely aggressive. Not a reduced rate — the sponsor fee was waived entirely, to zero, on the first $2.5bn of assets. For a category where the cheapest permanent fee is 0.14%, giving away the whole thing was about as far as an issuer could go to buy market share.

The catch was in the construction. The waiver was written to expire on 31 July 2026 regardless of whether the fund ever reached $2.5bn. It was a date, not a condition. And HODL did not get there: the fund held about $1.076bn on 30 July 2026, roughly 43% of the threshold and $1.4bn short. On 1 August 2026 the full 0.20% switched on for every holder, including people who had bought on the strength of the zero fee and had done nothing since.

It is worth being precise about who is at fault here, which is nobody. VanEck disclosed the expiry date. The prospectus said what it said. Nothing was hidden and nothing was changed mid-flight. The gap was entirely between what the marketing communicated — a free fund until it gets big — and what the document actually promised, which was a free fund until a specific Friday in July.

The small print

The general lesson, drawn properly

A fee waiver is a marketing instrument with terms, and the terms matter more than the headline. There are three ways an issuer can end one — a date, an asset threshold, or whichever comes first — and the difference between them decides whether the offer is worth anything to you. A threshold-based waiver on a fund that grows fast can end in months. A date-based waiver on a fund that never grows, like HODL's, runs its full course and then stops anyway.

HODL is not an outlier. Every significant waiver in the category has now lapsed:

• IBIT — 0.12% introductory rate on the first $5bn, twelve months from launch. Expired January 2025; BlackRock's own quarterly filing confirms no fees were waived in the first half of 2026. Details on the IBIT profile.
• FBTC — Fidelity's 0% promotion, which ended on 31 July 2024. The fund has charged its unified 0.25% ever since. See the FBTC profile.
• HODL — 0% on the first $2.5bn, expired 31 July 2026 with the fund at 43% of the target.
• BITB, BTCO, EZBC and BTCW — all launched with introductory promotions, all of which have run out.

The practical rule that falls out of this: when you are comparing funds, compare the headline fees, treat any waiver as a temporary discount, and check the expiry clause before you let it influence the decision. If a waiver is the reason a fund wins your comparison, the fund does not really win. We run the numbers on the permanent rates on the Bitcoin ETF fee page.

Is 0.20% actually a problem?

No, and it would be unfair to leave the impression that it is. HODL at 0.20% is cheaper than IBIT and FBTC at 0.25%, cheaper than CoinShares' BRRR, Invesco's BTCO and WisdomTree's BTCW at the same 0.25%, and dramatically cheaper than GBTC at 1.50%. On a $50,000 position the difference between HODL and IBIT is $25 a year in HODL's favour.

It is not the cheapest. The Grayscale Mini Trust charges 0.15% and Morgan Stanley's MSBT charges 0.14%, which became the category floor when it launched in April 2026. Franklin's EZBC undercuts HODL slightly at 0.19%, though on much thinner liquidity. So a HODL holder is paying five or six basis points above the best available rate — $50 to $60 a year per $100,000 — in exchange for a fund from an established issuer with a decent liquidity profile.

That is a perfectly defensible position to be in. The problem was never the price. The problem was that a cohort of investors believed they were in a free fund and discovered otherwise on a Saturday morning.

Custody — a question we cannot close

HODL's custodian is most commonly reported as Gemini Trust Company, which would make it one of the very few US spot funds not routing through Coinbase Custody. But sources conflict, and some indicate a multi-custodian arrangement rather than a single provider. We have not been able to settle it to a standard we would publish as fact.

So: the position is unresolved. If custody is a deciding factor for you, read VanEck's current prospectus rather than relying on any directory, including this one. And if what you want is a documented answer to custody concentration — roughly 80% of all ETF-held bitcoin sits with Coinbase Custody — then ARKB's three-way split and FBTC's in-house custody through Fidelity Digital Assets are the two funds where the arrangement is clearly documented. We map the whole custody picture on the issuers and custodians page.

Creation, authorised participants and in-kind

VanEck's FY2025 annual report names four authorised participants: Jane Street, Virtu Americas, Macquarie Capital and ABN AMRO Clearing USA. That is a shorter list than IBIT's thirteen, but the composition matters more than the count — Jane Street, Virtu and Macquarie appear in the AP roster of every major fund in the category, and they are the firms that actually do the arbitrage work that keeps a fund's price near its net asset value.

HODL is named in the SEC's in-kind order of 29 July 2025, under the Cboe BZX rule alongside ARKB, FBTC, BTCW, BTCO and EZBC. In-kind creation lets an authorised participant deliver bitcoin for shares rather than routing everything through cash, which tightens the arbitrage loop. Whether it is running at volume for HODL specifically is not something the filings we have make clear. The mechanism itself is explained in how Bitcoin ETFs work.

Who should hold HODL

HODL suits an investor who wants a below-average fee from a long-established issuer and does not need the deepest options market or the tightest spread in the category. It is a reasonable core holding. It is a perfectly sensible pick for someone building a position across two or three funds to avoid concentrating in a single trust.

It is the wrong pick if cost is your only criterion, where the Mini Trust and MSBT win. It is the wrong pick if you trade options, where nothing touches IBIT. And it is the wrong pick if you need a documented custody arrangement, because that is precisely the thing about HODL that we cannot verify. If you are still deciding between funds rather than between fund and coin, our opinionated picks across the crypto ETF market and the step-by-step guide to buying one are the next two pages to read.