An active “asset manager” disclosure can still leave provider identity, economics and authority unresolved.
Onfolio Holdings provides a useful role-boundary control. Its 2025 annual report and both 2026 quarterly filings say one third-party asset manager manages and stakes ETH and SOL on the company’s behalf. The same filings separately identify BitGo as custodian / principal market and describe a validator-operator layer. The reviewed filings do not identify the third-party asset manager or disclose a manager fee, term or exit schedule.
Current public record
| Field | Observed disclosure |
|---|---|
| Issuer | Onfolio Holdings Inc. (ONFO) |
| Treasury assets | BTC, ETH and SOL; ETH and SOL are used in native staking. |
| Manager disclosure | One third-party asset manager is described as managing and staking ETH and SOL on Onfolio’s behalf. |
| Custody | BitGo is identified separately as the single third-party custodian and principal market used for digital-asset fair-value pricing. |
| Validator layer | The filings describe a third-party validator operator, using BitGo as an example, that manages staking process / delegation to network validators. |
| Manager identity | Not identified in the reviewed 10-K or March / June 2026 10-Q text. |
| Manager economics | No manager fee, term or exit schedule was located in the reviewed filings. |
| Currentness | ACTIVE STAKING-MANAGER ROLE DISCLOSED / PROVIDER IDENTITY + MANAGER ECONOMICS NOT PUBLICLY LOCATED IN REVIEWED FILINGS |
The role label does not identify the counterparty
The filing language establishes that a third-party asset manager exists and is active in ETH / SOL staking. It does not establish that BitGo is that asset manager. BitGo is separately identified as custodian / principal market, while the filing also describes a validator-operator function. Those layers should not be collapsed into one provider simply because the same name can appear in custody or validator examples.
This case should not enter a clean manager-rate table
The reviewed public text does not provide enough evidence to normalize a broad discretionary portfolio-management mandate or a recurring manager fee. The disclosed function is specifically tied to managing and staking ETH and SOL, and the filing says the company retains the ability to direct use of the assets and obtain substantially all benefits. Without a located manager agreement or equivalent primary terms, comparing this relationship directly with a full discretionary DAT manager would manufacture precision the public record does not support.
The gap persists across multiple reporting dates
The December 31, 2025 annual filing disclosed the third-party manager relationship. The March 31 and June 30, 2026 quarterly filings repeated the same manager / staking description. That persistence supports an active-role currentness state while leaving provider identity and economics unresolved.
Why this matters for a provider-economics stress test
A public-company treasury can disclose active use of an external “asset manager” without publishing enough information to construct a fee comparable. That creates a different problem from a pre-signing case: the role is active, but the counterparty and economics remain incomplete in the reviewed public record.
Primary public sources
2025 Form 10-K — digital assets, BitGo custody and third-party staking manager
March 31, 2026 Form 10-Q — manager relationship repeated
June 30, 2026 Form 10-Q — manager relationship still disclosed
Related research
Pre-signing provider currentness →
Benchmarking and disclosure evidence →
Compare executed management agreements →
Currentness methodology →
Public-source factual commercial research only. “Not publicly located” describes the reviewed public record and does not establish that no non-public agreement exists. No legal, fairness, fiduciary, accounting or investment opinion.