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Winklevoss Asset Services filed a preliminary registration statement on October 6, 2026, proposing a Zcash exchange-traded product that would hold ZEC directly and trade on Nasdaq under the ticker WINK. The proposed annual sponsor fee is 0.25%. The filing is not an approval or confirmation that shares are trading: it says the registration statement is incomplete and shares cannot be sold until it becomes effective.
What the proposed WINK Zcash ETF would do
The Winklevoss Zcash ETF is structured as a passive trust intended to hold Zcash (ZEC) and reflect the value of its holdings, less expenses and liabilities. It would not seek to outperform ZEC. The filing proposes a Nasdaq listing under WINK, subject to notice of issuance. SEC Form S-1, filed October 6, 2026.
The preliminary S-1 describes the Trust as not registered under the Investment Company Act of 1940. Shareholders therefore would not receive protections that apply to funds registered under that Act; this is not a conventional registered mutual fund.
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The proposed unified Sponsor Fee is 0.25% annually of the Trust’s ZEC holdings. It would accrue daily based on the prior day’s holdings and be payable monthly in ZEC or cash. The sponsor says it would use the fee to cover normal operating expenses.
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That fee is not a complete estimate of every possible cost. Defined extraordinary, nonrecurring expenses—including certain transaction, tax, indemnification, and legal costs—could instead be charged to the Trust. Investors buying or selling through a broker would also incur customary brokerage commissions and charges. Shares could trade above or below the Trust’s net asset value (NAV).
Who would manage and custody the ZEC
Winklevoss Asset Services, LLC, wholly owned by Winklevoss Asset Services Holdings, LLC, is the proposed sponsor. Gemini Trust Company, LLC, an affiliate of the sponsor, is named as custodian. The filing says Gemini would safeguard private keys and keep the Trust’s ZEC in segregated cold-storage addresses, except as needed for temporary operational purposes.
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Cypherpunk Technologies Inc. is named as the Zcash Ecosystem Partner. The filing describes possible support in advisory work, protocol development, and coinholder polling.
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Is WINK approved or trading?
Not on the evidence in the preliminary S-1. The October 6, 2026 filing proposes a product and anticipated Nasdaq ticker; it does not establish that the registration statement has become effective or that trading has begun. The filing itself says its information is incomplete and may change, and that the securities may not be sold until the registration statement is effective. Check for a later SEC filing before treating the proposed terms or trading status as final.
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Several details are left blank in the reviewed filing: the benchmark provider and index, transfer agent, administrator, cash custodian, basket size, seed investor, and seed-share details. Those terms should not be assumed from the proposed ticker or sponsor.
Investment risks disclosed in the filing
The sponsor warns that WINK shares would be speculative, could trade at a premium or discount to NAV, and could lose their entire value. Its prospectus states: “THE SHARES ARE SPECULATIVE SECURITIES. THEIR PURCHASE INVOLVES A HIGH DEGREE OF RISK AND YOU COULD LOSE YOUR ENTIRE INVESTMENT.” This is the issuer’s warning, not an SEC endorsement or independent SEC assessment.
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The filing also discusses Zcash privacy technology and a network-security incident. Shielded Zcash transactions use zk-SNARKs to protect transaction amounts, senders, and recipients. According to the S-1, a vulnerability in the Orchard shielded pool was identified in late May 2026 and addressed by an emergency network upgrade in early June. Developers reported no evidence of exploitation, but the filing says the privacy-preserving system cannot conclusively establish whether exploitation occurred before remediation.
What the $100 million indication means
Winklevoss Capital Fund, LLC indicated nonbinding interest in purchasing up to $100 million of shares through affiliates. The filing says the purchaser could buy more, fewer, or no shares. It is not a commitment, completed investment, or guarantee of demand.
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