Performance Update

As of January 2026, Bursera Capital's total ROI is 650.41%* since the fund's inception in 2019, with Bitcoin standing at 659.98% and the average fund reaching 527.43%. Returns are -12.68%*, with the average fund reporting 8.01% and Bitcoin at -9.97%. Our Compound Annual Growth Rate (CAGR) is 36.35% with Bitcoin at 36.62% and the average fund at 32.65%.

Performance Analysis

While 2025 year-to-date performance has moderated, Fund II has demonstrated Bursera's ability to operate at scale—an essential foundation for long-term capital deployment. Since inception, the fund has consistently generated BTC-denominated returns while materially expanding assets under management, validating both the durability of the strategy and management's ability to deploy incremental capital efficiently across varying market environments.

Critically, yield generation has remained resilient throughout periods of both BTC price appreciation and consolidation, indicating that performance is driven by execution rather than directional exposure. Capital Gains Yield as a percentage of AUM (6-month moving average) has remained robust, consistently ranging between 0.75–2.5% in recent periods. On an annualized basis, this implies a Capital Gains Yield profile of approximately 13.4% and a cumulative 42.5% monthly Capital Gains Yield since inception, materially outperforming traditional fixed-income alternatives and passive BTC holding strategies.

Importantly, these yields have been maintained alongside significant net inflows and the realization of profits through partial and full position exits. The strategy has continued to generate Capital Gains Yield while onboarding new capital and recycling liquidity from sold positions, demonstrating scalability without reliance on static portfolio construction or one-time opportunity capture.

Overall, the data suggests meaningful runway for continued AUM/Principal growth without proportional yield degradation. While some compression from early-stage yields is expected as capital scales—consistent with capacity dynamics across all alpha-generating strategies—current performance indicates substantial remaining capacity. Management remains focused on optimizing execution and expanding the opportunity set to support continued growth.

Market News

Tensions Flare Between Stablecoin Issuers and Traditional Banks as Crypto Legislation is being Finalized by Congress.

Stablecoin Yield Emerges as Flashpoint in Crypto Market Structure Legislation

As Congress works to finalize the CLARITY Act, the fight over whether stablecoin balances can earn yield has become the primary point of contention between the banking sector and the crypto industry. The GENIUS Act, signed into law in July 2025, established the first federal framework for payment stablecoins and prohibits stablecoin issuers from paying interest or yield directly to holders. However, crypto platforms including Coinbase argue that third-party rewards and incentive programs offered through exchanges or affiliates are not covered by that prohibition, maintaining that such arrangements fall outside the statute's text. Traditional banking groups are pushing back aggressively, urging regulators and Congress to interpret or amend the law so that no entity can offer yield on stablecoin balances. They argue that yield-bearing stablecoins could draw deposits away from banks and undermine lending capacity and financial stability. Legislative momentum reflects this pressure point: recent Senate drafts of the market-structure bill would bar digital asset platforms from paying interest solely for holding stablecoins, while still allowing activity-based rewards in some forms. The outcome of these deliberations will shape the competitive landscape between traditional banking and digital asset platforms, influencing where deposit-like yields can be offered and under what regulatory constraints.

The Stakes for Traditional Banking: The Dual Threat of Stablecoins

The intensity of the banking lobby's opposition reflects the scale of revenue at risk. Stablecoins threaten two of traditional banking's largest income streams simultaneously, and understanding both is essential to decoding the politics of this legislative fight.

On the deposit side, U.S. banks earn approximately $176 billion annually on roughly $3 trillion parked at the Federal Reserve, while paying depositors near-zero interest rates. Stablecoin platforms threaten this spread directly. If they can offer users even a portion of Treasury bill yields (currently in the 3-5% range), they create a parallel system where retail and institutional users can earn returns without routing dollars through traditional bank balance sheets. This does not eliminate bank lending capacity outright, as stablecoin issuers hold reserves in Treasury bills and bank deposits, but it fundamentally shifts who captures the margin.

On the payments side, U.S. card payments processed $11.9 trillionin purchase volume in 2024, with merchants paying an average of 1.57% per transaction in acceptance and processing fees—totaling $187 billion annually, or nearly $1,400 per household.Stablecoins bypass this infrastructure entirely; on-chain payments cost a fraction of card network fees. If stablecoins capture just 5% of card purchase volume, that represents $9.4 billion in foregone revenue for banks and card networks. At 10% market share, that figure doubles to $18.7 billion. The eight largest card issuers account for over 90% of Visa, Mastercard, and American Express transactions, meaning this displacement would concentrate losses among the same institutions leading the lobbying effort against stablecoin yield.

Why Banks Are Fighting on Yield, Not Payments

Banks are lobbying aggressively on the yield question, framing it as a matter of "financial stability" and "deposit flight." But this may be misdirection. The yield battle is winnable through legislation—Congress can define what counts as prohibited interest and close the rewards loophole. The payment rail disruption is harder to stop. You cannot pass a law making stablecoins expensive to transfer.

If stablecoins offer yield and cheap payments, they become a full deposit substitute—savings account, checking account, and payment card in one. That is the nightmare scenario for traditional banking. If Congress kills the yield, stablecoins remain a superior payment rail, but become less attractive as a place to park money long-term. Banks may lose the war on payments, but they are fighting to win the battle they can.

Legal Ambiguity in Current Arrangements

The legal permissibility of existing distribution agreements remains contested. A recent analysis from Columbia Law School argues that Circle may already be violating Section 4(a)(11) of the GENIUS Act through its revenue-sharing arrangement with Coinbase. Circle's S-1 filing concedes that the greater the proportion of USDC held on Coinbase's platform, the greater the share of reserve income payable to Coinbase: an arrangement that Circle paid $907.9 million to Coinbase in 2024 alone. Under prevailing crypto-asset law, federal guidance, and Coinbase's own litigation positions regarding asset control, Coinbase, not its retail customers, may be the legal "holder" of USDC in custodial wallets. If so, Circle is paying interest to a holder solely for holding the stablecoin, which maps directly onto the statutory prohibition. This ambiguity underscores the need for legislative clarity: without it, enforcement remains uncertain and market participants operate in a gray zone that benefits no one.

Deposit Flight Concerns May Be Overstated

Despite the banking industry's warnings, independent research suggests that the deposit flight scenario may be less severe than advertised. Charles River Associates, in research commissioned by Coinbase, found no statistically significant relationship between USDC growth and community bank deposits using monthly data from 2019 to 2025. Even under harsh assumptions, community banks would lose less than 1% of deposits in a baseline scenario and 6.8% in an extreme case. Cornell researchers reached a similar conclusion: rewards would need to approach 6% to meaningfully affect deposit balances. Current stablecoin reward programs range from 1% to 3%—competitive with high-yield savings accounts but not transformative enough to trigger mass migration. Some analysts argue that the real competitive threat to banks is not yield itself, but the rise of wallet apps and fintech platforms that retain customers through superior utility—faster settlement, cheaper cross-border payments, and tighter integration across financial activities. Yield may attract deposits, but utility determines where they stay.

Win-Win for Bursera

Bursera's strategy is not dependent on stablecoin yield, which insulates the fund from direct impact regardless of how this legislative battle resolves. We maintain stablecoin exposure solely for operational liquidity, facilitating trade execution and settlement, rather than as a yield-generating instrument. This positions us to operate without disruption under either regulatory outcome.

That said, the more significant variable for Bursera and the broader institutional market is not which side prevails, but whether Congress delivers regulatory clarity at all. A definitive resolution, whether it restricts platform-level rewards or permits them, provides the legal certainty that institutional allocators require before deploying meaningful capital into digital assets. The least favorable scenario would be prolonged legislative gridlock or a breakdown in bipartisan support that leaves market participants operating under ambiguity. Clarity, even imperfect clarity, accelerates institutional adoption and deepens the liquidity environment in which Bursera operates.

We will continue to monitor the CLARITY Act's progress and assess any second-order effects on our exchange relationships and treasury management practices as the final legislative text takes shape.

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*Data from January 2026 subject to crystallization.