Roxom Letter to MSCI

To: Henry A. Fernandez Chairman and Chief Executive Officer MSCI Inc.

Re: Comments on Proposed Exclusion of Bitcoin Treasury Companies from MSCI Indices

Dear Mr. Fernandez,

Roxom appreciates the opportunity to comment on MSCI’s proposed exclusion of companies whose digital asset holdings exceed 50% of total assets from the MSCI Global Investable Market Indexes.

Roxom is a Bitcoin-native capital markets firm focused on research, analytics, and market infrastructure for publicly listed Bitcoin Treasury Companies (“BTCTCs”). Our work spans global equity markets and institutional investors who rely on MSCI benchmarks as neutral representations of the investable universe.

We are concerned that the proposed 50% digital-asset threshold introduces methodological inconsistencies that would materially weaken index neutrality and comparability.

1. Business activity, not balance-sheet composition, defines an operating company

Equity indices have historically classified companies based on what they do, not how their assets are composed.

• Energy companies are not excluded because oil reserves dominate their economic value.
• Real estate firms are not excluded because property comprises most of their balance sheet.
• Gold miners are not excluded because commodity exposure drives valuation.

Bitcoin Treasury Companies are operating businesses that raise capital, manage liabilities, pursue acquisitions, and generate shareholder returns using Bitcoin as a treasury asset. Crossing an arbitrary asset-percentage threshold does not change the nature of their business.

A company does not become a different economic entity at 49% versus 51% exposure to a single asset.

2. The 50% threshold creates non-economic cliff effects

Under the proposal, two otherwise identical companies would face radically different index treatment solely due to short-term asset price movements.Nothing changes operationally, yet index eligibility flips.

This introduces unnecessary turnover, tracking error, and implementation risk for passive investors outcomes that run counter to the purpose of broad market benchmarks.

3. Inconsistent treatment versus other asset-intensive business models

MSCI does not apply asset-concentration tests to companies whose value is primarily driven by:

• Oil and gas reserves • Gold production and royalties • Real estate portfolios • Financial firms holding large securities inventories

Applying a unique exclusion rule to Bitcoin alone establishes a precedent for asset-based index engineering that is neither historically grounded nor methodologically consistent.

4. Customization already solves client concerns

We recognize that some asset owners may wish to limit exposure to Bitcoin-focused companies. MSCI already provides robust tools to address this including custom indices, exclusions, and overlays without redefining the core equity universe for all investors.

Preserving neutral flagship indices while offering opt-in customization maintains methodological integrity and client choice simultaneously.

Conclusion

Roxom supports both Bitcoin-enabled corporate innovation and the principles of passive investing. These are not mutually exclusive.

We respectfully submit that excluding operating companies based on an arbitrary digital-asset threshold would undermine index neutrality, introduce inconsistency across asset classes, and impose unintended costs on passive investors.

We encourage MSCI to maintain equal treatment across asset types and allow markets — not accounting thresholds to determine winners and losers.

Sincerely,

Roxom Team

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