Texas Treasury’s Bitcoin Stash: The 13F Discrepancy That Tells a Deeper Story

Maxtoshi Law

The data shows a contradiction. On June 30, 2026, the Texas Treasury Safekeeping Trust Company (TTSTC) reported holding 197,844 shares of the iShares Bitcoin Trust (IBIT) in its quarterly 13F filing. The filing value: $6.62 million. But the market value of those shares on that date, based on IBIT’s NAV of $33.48, was exactly $6.62 million—a clean match. The problem? The prior quarter’s filing, for March 31, 2026, also listed 197,844 shares, but at a filing value of $7.64 million, derived from IBIT’s then-NAV of $38.62. That means the March filing was updated to reflect the market price, but the June filing did not adjust the share count. Yet the article that broke this story claims the value dropped from $10 million to $6.62 million, implying a 33.8% loss. Let me break down the forensic trail.

Context: The Strategic Bitcoin Reserve, Step One

In early 2026, the Texas legislature allocated $10 million from the state’s Economic Stabilization Fund to establish a Bitcoin strategic reserve. The legislation, signed by the governor, directed TTSTC to acquire Bitcoin through a regulated, SEC-approved vehicle first—IBIT—before building the infrastructure to custody the underlying asset directly. This was a two-phase plan: Phase 1, ETF exposure; Phase 2, direct on-chain custody. The $10 million bought 197,844 IBIT shares at an average entry price of approximately $50.50 per share, implying a Bitcoin price of roughly $50,500 at the time of purchase. By the end of Q2 2026, Bitcoin had fallen 13.25% to around $43,800, and IBIT’s NAV followed suit, dropping 13.31% to $33.48. The position’s market value fell to $6.62 million. The 13F filing for Q2, however, reported the same 197,844 shares—no reduction, no addition. The filing value of $6.62 million matched the NAV. So far, so clean.

But here’s the detection: The original article states that the “12F filing value” (likely a typo for 13F) was $6.62 million, down from $10 million. That $10 million figure is the original allocation, not the filing value at the end of Q1. The Q1 13F filing, which I audited via the SEC EDGAR database, listed the value as approximately $7.64 million (197,844 shares × $38.62 NAV). The drop from $10 million to $7.64 million occurred in Q1; the drop from $7.64 million to $6.62 million occurred in Q2. The total realized loss from allocation to end of Q2 is $3.38 million, or 33.8%. The article conflated the allocation amount with the filing value, creating a misleading narrative of the loss timeline. This is a common error in crypto media—mixing capital committed with portfolio value reported.

Core: The On-Chain Evidence Chain

IBIT is an ETF, not a direct blockchain asset. But the on-chain data for Bitcoin provides the ultimate proof of custody. Let me walk through the evidence chain:

  1. NAV Verifiability: BlackRock publishes IBIT’s NAV daily. On March 31, 2026, the NAV was $38.62. On June 30, 2026, it was $33.48. The price drop is 13.31%, nearly identical to Bitcoin’s 13.25% decline—confirming the ETF tracks the spot price within 0.06% tracking error. No hidden alpha or beta.
  1. Share Count Consistency: The 13F filings for both Q1 and Q2 show 197,844 shares. This indicates no tax-loss harvesting, no rebalancing, and no partial sale. The state is holding static. The lack of activity is itself a signal: they are not treating this as a trading position.
  1. Filing Value Discrepancy: The March 31 filing value (7.64M) is updated from the original $10M cost basis. The June 30 filing value (6.62M) is updated from the March value. This is standard accounting—mark-to-market. But the share count remained unchanged. If the state had sold any shares, the count would have dropped. It didn’t. So the position is intact.
  1. Baseline for Loss: The average cost basis is approximately $50.50 per share. At $33.48, the unrealized loss is 33.8%. But this is a paper loss—no cash exits the treasury until they sell. The state’s accounting rules likely treat this as a “temporary impairment” unless they intend to sell.

The Contrarian Angle: Why the ‘Holding’ Might Be a Trap

Conventional crypto narrative says “Texas is HODLing Bitcoin—bullish.” But the data suggests a more nuanced reality. First, the $10 million allocation is less than 0.0006% of TTSTC’s total $1.65 trillion in assets under management. This is a rounding error, not a strategic bet. Calling it a “strategic reserve” is political theater—the real financial impact is negligible.

Second, the lack of selling might not be conviction. It could be a sunk cost trap. If the state sells now, it locks in a $3.38 million loss, which becomes a political liability. Holding allows the loss to remain unrealized, shifting the narrative to “long-term investment.” The 13F silence on intent reinforces this: they disclose the position but not the strategy.

Third, the 13F filing itself reveals a data quality issue. The Q1 filing value was $7.64M, but the article incorrectly reported the original $10M as the Q1 value. This is not a minor error—it changes the loss timeline. If the media can’t get the filing numbers right, how can the public trust the broader narrative? This is a systemic problem in crypto reporting: journalists rarely verify the source documents.

Texas Treasury’s Bitcoin Stash: The 13F Discrepancy That Tells a Deeper Story

Takeaway: The Signal in the Noise

The Texas IBIT position is a marginal data point in a $1.65 trillion portfolio. The real story is the 13F filing discrepancy—not the number itself, but the sloppy reporting around it. Next quarter, I’ll be watching for two things: (1) whether the share count changes, signaling a move to direct custody, and (2) whether the state discloses a hedging strategy to protect against further downside. If they do neither, this is a dormant position, not a dynamic reserve. Liquidity doesn’t lie. The on-chain flow of Bitcoin from ETFs to cold storage will tell us if Texas is serious. Until then, follow the data, not the hype.

Forensics reveal what PR hides. The 13F data is clean; the narrative around it is not.

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