# The Rulebook: running a fund day to day

**ETP Foundry (formerly CrossDesk). Version 0.3 DRAFT, 19 October 2026.**

> **In short.** This is the process side of running a tokenized fund on Canton with ETP Foundry: who does what each day, what happens when a value cannot be made, how rules change, how a fund winds down, and what is recorded. The rules themselves are in Methodology v1.1, which governs wherever this document differs. ETP Foundry calculates and proposes; the fund's own parties sign. ETP Foundry never signs, and no seat it runs ever counts. Canton DevNet only; not registered with any regulator; code not audited.

> **What changed from v0.2.** v0.2 (28 September 2026) was the rulebook for the retired price-fixing product: index construction, venue eligibility, strikes, the input waterfall, the sealed auction, the band, the tier 0–5 scale, the 0.10% same-day restatement test and benchmark licences. v0.3 keeps only the process that is still true and restates it for funds, under Methodology v1.1. Complaints (2 business days to acknowledge, 20 to answer) and corrections (the NAV error policy) now match the Methodology; in v0.2 they differed and the Methodology already prevailed. What was dropped is listed in the appendix.

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## 1. Precedence

- Methodology v1.1 is the governing text. This rulebook describes process only, and has no force where it differs from the Methodology.
- A fund's own legal documents govern the fund. Where they set a stricter rule, theirs applies.
- Every version is kept on file. Nothing here is a rule a fund has adopted yet: no fund has outside parties seated.

## 2. The parties

| Party | Does |
|---|---|
| Sponsor | Name on the fund; owns the legal wrapper; picks the administrator and custodian; signs basket changes, fees, compliance actions, suspensions and wind-down; co-signs the NAV. Can never reach K alone |
| Reserve signer (each token's issuer) | Confirms its own token is fully backed |
| Administrator | Recomputes the NAV from its own reads and signs it, or refuses |
| Custodian (if assets sit off the ledger) | Confirms the fund's holdings match the ledger |
| Transfer agent (optional) | Confirms the share count; co-signs compliance actions |
| Lender (optional) | Checks the NAV against its own value, within a tolerance declared in advance |
| Market maker | Creates and redeems shares; approved by a compliance action |
| ETP Foundry | Sets up the fund, calculates and proposes, settles creations and redemptions, keeps the record. Never signs |

Asset prices come from existing providers named in the fund's terms (Chainlink, Kaiko or others). ETP Foundry is not a price provider.

## 3. The daily cycle

1. **Valuation point.** Crypto funds: 16:00 London, every day. Funds with stocks: 16:00 New York on NYSE trading days. Treasury and credit funds: 16:00 New York on US business days.
2. **Read.** The engine reads the fund's holdings from the ledger and each asset's price from the source the fund names, in the agreed order (Methodology §3.3).
3. **Propose.** The engine proposes the NAV once, with every input attached. If an asset has no fresh price, nothing is proposed and the reason is recorded.
4. **Sign or refuse.** Each seat's checker recomputes from its own data and signs as its role, or refuses with a reason.
5. **Finalise.** Once K counted signatures and the required roles are in, the NAV is recorded on the ledger.
6. **Deal.** Market makers create and redeem at the next signed NAV after their order, one atomic transaction each.

No person needs to click anything on a normal day.

## 4. When a value cannot be made

| Situation | What happens |
|---|---|
| A price is refused | The engine proposes again without that source, moving to the next one. At most 3 proposals per fund per day |
| No usable price source is left | Escalated: the seats may sign a fair value. The engine does nothing further |
| Reserves, holdings or shares refused | Not re-proposed. Every party is alerted with the numbers |
| Not signed by valuation point + 2 hours | Recorded as missed. Nothing is carried forward automatically. The last signed NAV stays visible with its date |
| A price is stale | Carried forward for one valuation point at most, flagged, and only with the administrator's signature. After that, no NAV and no dealing until there is one |
| A real problem (for example reserves fall short) | Any one of the sponsor, administrator, a reserve signer, the custodian or the transfer agent may pause creations and/or redemptions for 1 to 72 hours. A pause never moves a number |
| Longer than 72 hours | A suspension, signed by the full quorum, with a reason and a review date |

**Never guess.** A value that cannot be made is published as a gap with its reason.

## 5. Refusal

Refusing is the mechanism working. A refusal is recorded with the seat's numbers and reason, and is visible to every party on the fund. It is never held against a seat. A seat that keeps refusing without stated cause may be reviewed under the Committee terms (v1.4).

## 6. Corrections

A wrong value or action is corrected by a new record under the same quorum, stating why the original was wrong. The original is never deleted. A NAV error of 50 bp or more (half a cent per share for a stable-NAV fund) is material: trades struck at the wrong NAV are reprocessed or compensated, and market makers, holders and lenders relying on it are told (Methodology §6.6). A value is corrected only for a wrong input or a misapplied rule, never because the result was unpopular.

## 7. Changing the rules

1. A **material** change to the Methodology needs at least 30 days of public consultation, a published summary of responses, then at least 30 days' notice.
2. Clarifications take effect on publication.
3. Every version is kept and every NAV is read under the version in force on its date.
4. **No retroactive change, ever.**
5. A change to a fund's basket is a fund action signed by the sponsor and the administrator, with notice first, and must not move the NAV.

## 8. Wind-down

A fund is wound down by an action signed under the full quorum, stating the reason, the last creation date, the final redemption date and how remaining assets go back to holders. **The final redemption is at least 60 days after notice**, enforced on the ledger. If ETP Foundry itself stops, see Business continuity (v0.2).

## 9. Records, conflicts, complaints

- **Records.** Every signed fund action is permanent on the ledger: terms, who proposed, who signed, whether each signature counted, the evidence, and for a correction what it replaced and why. Every submission, refusal and missed deadline is in an append-only event log. Retention: at least five years (Methodology §9.4); ETP Foundry's records policy is seven years.
- **Conflicts.** See the conflicts policy (v0.3). Each seat declares its conflicts before it signs anything.
- **Complaints.** In writing to committee@etpfoundry.com; acknowledged within 2 business days, answered within 20, with reasons.

## 10. Labels

Every value says what it is: **signed** (K counted signatures, each named with its role and key level), **indicative** (calculated, signed by nobody who counts), or **missed** (a gap, with the reason). Each price shows its source and level.

**Never presented otherwise:** an indicative value as a signed one; any value as signed by an outside party before one is; ETP Foundry as authorised or registered anywhere.

## 11. Regulatory posture

- ETP Foundry is not authorised or registered with any regulator, and says so on every surface.
- Where a jurisdiction requires a licensed administrator, custodian or transfer agent, that firm keeps the role and holds the seat.
- A real fund needs a sponsor, its legal structure, an administrator and any required registrations, set up with counsel before launch.

## 12. The documents we publish

| Document | Current version |
|---|---|
| Methodology | v1.1 |
| What we ask of each seat | v3 |
| Committee terms of reference | v1.4 |
| This rulebook | v0.3 |
| Conflicts of interest | v0.3 |
| Complaints, consultation and corrections | v1.1 |
| Security overview, privacy notice, sub-processors, AI use, incident response, business continuity | see etpfoundry.com/documents |

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## Appendix: retired from v0.2

Not in force. Kept on file as a record.
- Index construction (§4 of v0.2): venue eligibility, universe, weighting, rebalancing, divisor, corporate actions, naming, multi-network assets.
- Fixing rules (§5): strike schedule, input waterfall, sealed auction, thin-market rule, band, wrapper factor, class D and class F specifics.
- Price-committee composition by asset class (§6), except the key levels L1/L2/L3, which are in Methodology v1.1 §5.
- The tier 0–5 scale, `CARRIED FORWARD` / `EXCEPTIONAL` fixing flags, and the 0.10% same-day restatement test (§7).
- Benchmark licence classes and benchmark-administrator registration costs (§11, §12).
- The IOSCO benchmark mapping (§13) and the eight open items for a price committee (§14).

*ETP Foundry is a trading name of Lucilla, Inc., Toronto. Nothing here is investment advice or an offer of any financial product.*