Tokenized interval funds combine a fund registered under the Investment Company Act of 1940 with blockchain infrastructure for recording and transferring fund shares. ARK Venture Fund’s Ethereum initiative offers asset managers and blockchain businesses a concrete example of how that combination can work, including the regulatory permissions, operating decisions, and liquidity limitations involved.

On September 24, 2026, ARK Invest and Securitize announced the tokenization of ARK Venture Fund (ARKVX). The announcement identified Ethereum as the initial network and Securitize as the infrastructure provider. ARK’s portfolio includes private and public companies, with OpenAI, Anthropic, Stripe, and Databricks among the holdings named in the release. The release uses forward-looking language about availability upon release, so there is no guarantee that an liquid secondary market will open as planned.

For blockchain curious product developernt teams at mainstream asset managers, the September 21 SEC exemptive order is especially instructive. It accommodates conventional, exchange-listed, and tokenized share classes within a registered closed-end fund framework.

What is a tokenized interval fund?

An interval fund is a closed-end investment company that periodically offers to repurchase a specified portion of its outstanding shares at net asset value, or NAV. Investors do not have an unconditional right to redeem daily. Repurchase offers may be oversubscribed, leaving investors unable to sell their entire positions.

Tokenization adds a digital method of representing fund-share ownership. In ARK’s proposed structure, a tokenized share represents an interest in the fund; the underlying portfolio companies are not themselves being tokenized. A blockchain can facilitate transfers of that interest without making the fund’s private assets immediately saleable.

This structure deserves consideration where investors value wallet access or digital distribution and can accept periodic fund liquidity. Product teams should start with the investment strategy and intended investor experience, then decide whether blockchain infrastructure improves delivery.

What ARK changed in its exemptive order

ARK first obtained an order on November 17, 2025, permitting multiple share classes, asset-based distribution and service fees, and early withdrawal charges. These are familiar features of multiclass registered alternative funds.

The earlier application represented that the funds’ shares would not be exchange-listed or quoted and that no secondary market was expected. ARK subsequently sought to remove that constraint. Its application states that recording ownership on a blockchain does not itself require exemptive relief; the amendment addressed the existing order and the proposed multiclass arrangements.

The September 2026 order permits an exchange-listed class and a tokenized class that may trade on alternative trading systems, or ATSs, or be quoted through other permitted channels. It grants specified Investment Company Act exemptions subject to the application’s conditions.

This is a precedent that other product sponsors can evaluate with counsel. The relief covers ARK and qualifying funds within the defined advisory group. An unaffiliated sponsor cannot simply adopt ARK’s order as its own authorization.

How ARK obtained the amended SEC order

The public record shows an application process lasting approximately four months from the initial amendment request to the final order. ARK Venture Fund and ARK Investment Management were the applicants; Dechert lawyers were listed as counsel in the notice.

• May 20, 2026 — ARK filed its application to amend the earlier order.
• June 11 and August 7 — ARK filed amended applications.
• August 24 — The SEC published notice of the requested relief.
• September 18 — The deadline for hearing requests expired.
• September 21 — The SEC issued the order, effective immediately. No hearing was requested or ordered.

This sequence gives prospective sponsors a useful planning example. It does not establish a standard approval timetable, disclose every staff discussion, or measure the time spent designing the product before the first filing. A new fund must also address registration and offering disclosures; an exemptive order is one component of the launch process.

Conditions that affect product design

The SEC notice sets out six conditions. Among them, funds must publish the prior business day’s NAV on a free public website and disclose that secondary trades may occur above or below NAV. Only approved wallets may hold tokenized shares, following identification, AML, and KYC reviews.

Costs specifically attributable to a class generally belong to that class. Exchange-required annual shareholder meeting costs are a specified exception. No early withdrawal charge may apply to the exchange-listed or tokenized classes.

These requirements belong in product specifications early. Teams should decide how wallet approval, account recovery, fee reporting, and investor communications fit together before finalizing the customer journey. A public blockchain can support a product with tightly controlled ownership and transfers.

Arca provides an earlier interval fund precedent

ARK is not the first interval fund to use Ethereum. Arca U.S. Treasury Fund launched in July 2020 with digital shares called ArCoin. Arca and Securitize announced secondary-market availability through Securitize Markets in July 2024.

Arca’s 2026 prospectus confirms that its shares are tradeable on that ATS, while describing a limited and relatively illiquid secondary market. It also explains that the transfer agent’s records govern legal record ownership; the blockchain holds a digital courtesy copy.

That detail matters for blockchain developers. Sponsors must establish which record controls, how discrepancies are resolved, and who can correct errors. The meaning of “onchain ownership” depends on the fund’s documented legal and operational arrangements.

Secondary trading does not guarantee liquidity

A trading venue provides a place to submit orders. Meaningful liquidity requires buyers willing to purchase sufficient shares at acceptable prices. Token issuance, wallet transfers, trading volume, and executed sales are different measures.

Consider a hypothetical investor with shares worth $100,000 at NAV. If the only bid covers $10,000 of that NAV at a 2% discount, the investor can receive $9,800 for that portion. The bid provides no assurance about selling the remaining position. Faster settlement cannot supply the missing buyer.

ARK’s application recognizes that investors seeking immediate liquidity might accept a discount rather than await a quarterly repurchase offer. The announcement itself continues to warn that liquidity is limited and repurchase offers may be oversubscribed.

A functioning secondary market could let one investor exit while another supplies the capital, reducing reliance on fund repurchases. Sponsors should measure this outcome through executed volume, bid sizes, spreads, discounts, and time to sell. An ATS listing alone cannot demonstrate it.

Building a tokenized 40 Act Fund

For asset managers, the commercial question is whether tokenization creates enough distribution or operating value to justify another share class and its supporting systems. For blockchain businesses, the starting point is the full registered-fund operating model: registration, governance, custody, disclosure, compliance, and reporting obligations remain relevant. The SEC’s registration guidance and Form N-2 provide starting references.

Who are the target investors? Specify investor eligibility, onboarding, wallet support, and distribution partners. Test demand with prospective buyers rather than treating the blockchain’s user count as the addressable market.

Who controls the records? Assign responsibility for the shareholder register, reconciliations, smart-contract changes, lost keys, mistaken transfers, and service-provider outages. Document which parties can freeze, reverse, or correct transactions where legally and operationally permitted.

How will money move? Separate subscription funding, share issuance, secondary settlement, and repurchase proceeds. ARK’s application discusses intermediary conversion of crypto assets into dollars; it did not request relief for the fund itself to accept crypto assets, including stablecoins, for subscriptions.

What is the liquidity plan? Design portfolio liquidity and repurchase funding without assuming secondary trading will absorb selling pressure. Budget for distribution, administration, transfer agency, custody, technology, and investor support alongside investment management.

ARK’s development expands the practical reference points for tokenized investment funds. Its lasting value for sponsors lies in the combination of a defined fund structure, explicit shareholder protections, and a documented path through SEC review. A successful launch will also need evidence that investors want the product and can use it reliably.

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