Bullish (BLSH) CEO Farley reports 5.05M-share incentive unit position

Rhea-AI Filing Summary

Bullish filed an initial insider ownership report for Chief Executive Officer Thomas W. Farley. He holds incentive units in subsidiary BMC1 that are exchangeable for up to 5,053,528 Ordinary Shares of Bullish upon vesting. The units vest based on time and performance conditions, and as of this filing, the underlying 3,370,308 Ordinary Shares are vested. No cash consideration is payable when the incentive units convert into Ordinary Shares.

SEC Form 3

FORM 3

UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

INITIAL STATEMENT OF BENEFICIAL OWNERSHIP OF SECURITIES

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934
or Section 30(h) of the Investment Company Act of 1940

OMB APPROVAL

OMB Number:			3235-0104
Estimated average burden
hours per response:			0.5

1. Name and Address of Reporting Person^*

Farley Thomas W

(Last) (First) (Middle)

OFFICE 101, 103, 105 SUITE 70202, BLDG A

BLOCK 7, 60 NEXUS WAY, CAMANA BAY

(Street)

GEORGE TOWN, GRAND CAYMAN KY1-9005

(City) (State) (Zip)

UNITED STATES

(Country)

2. Date of Event Requiring Statement (Month/Day/Year)
03/18/2026

3. Issuer Name and Ticker or Trading Symbol
Bullish [ BLSH ]

3a. Foreign Trading Symbol

5. If Amendment, Date of Original Filed (Month/Day/Year)

4. Relationship of Reporting Person(s) to Issuer
(Check all applicable)

X	Director		10% Owner
X	Officer (give title below)		Other (specify below)
	Chief Executive Officer

6. Individual or Joint/Group Filing (Check Applicable Line)

X	Form filed by One Reporting Person
	Form filed by More than One Reporting Person

Table I - Non-Derivative Securities Beneficially Owned
1. Title of Security (Instr. 4)	2. Amount of Securities Beneficially Owned (Instr. 4)	3. Ownership Form: Direct (D) or Indirect (I) (Instr. 5)	4. Nature of Indirect Beneficial Ownership (Instr. 5)

Table II - Derivative Securities Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security (Instr. 4)	2. Date Exercisable and Expiration Date (Month/Day/Year)		3. Title and Amount of Securities Underlying Derivative Security (Instr. 4)		4. Conversion or Exercise Price of Derivative Security	5. Ownership Form: Direct (D) or Indirect (I) (Instr. 5)	6. Nature of Indirect Beneficial Ownership (Instr. 5)
	Date Exercisable	Expiration Date	Title	Amount or Number of Shares
Incentive Units	(1)	(1)	Ordinary Shares	5,053,528	$0	D

Explanation of Responses:

1. Mr. Farley holds incentive units in BMC1, a subsidiary of Bullish, which are exchangeable for up to an aggregate of 5,053,528 Ordinary Shares of Bullish upon vesting. The incentive units are subject to time-based vesting and performance conditions. As of the date of this filing, 3,370,308 of the underlying Ordinary Shares are vested. No consideration is payable upon conversion.

Remarks:

Due to the issuer's status as a foreign private issuer pursuant to Rule 3a12-3(b) under the Act, the reporting person's transactions in the issuer's equity securities are exempt from Sections 16(b) and 16(c) of the Act.

	/s/ Thomas W Farley	03/18/2026
	** Signature of Reporting Person	Date
Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly.
* If the form is filed by more than one reporting person, see Instruction 5 (b)(v).
** Intentional misstatements or omissions of facts constitute Federal Criminal Violations See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).
Note: File three copies of this Form, one of which must be manually signed. If space is insufficient, see Instruction 6 for procedure.
Persons who respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB Number.
* Form 3: SEC 1473 (03-26)

FAQ

What insider position does Bullish (BLSH) CEO Thomas W. Farley report on this Form 3?

Bullish’s CEO Thomas W. Farley reports holding incentive units in subsidiary BMC1. These units are exchangeable for Bullish Ordinary Shares upon vesting, reflecting his equity-based compensation and alignment with shareholder outcomes over time.

How many Bullish (BLSH) shares are underlying Thomas Farley’s incentive units?

Thomas Farley’s incentive units are exchangeable for up to 5,053,528 Ordinary Shares of Bullish. This figure represents the maximum aggregate number of Ordinary Shares that could be issued upon full vesting and conversion of his incentive units.

How many of Bullish (BLSH) CEO Thomas Farley’s underlying shares are vested?

As of the filing date, 3,370,308 of the Ordinary Shares underlying Thomas Farley’s incentive units are vested. The remaining underlying shares are still subject to time-based vesting and performance conditions before they can become fully vested.

What vesting conditions apply to Thomas Farley’s Bullish (BLSH) incentive units?

Thomas Farley’s incentive units are subject to both time-based vesting and performance conditions. This means units vest gradually over time and only if specified performance targets are met, linking his potential equity to Bullish’s longer-term business results.

Does Thomas Farley pay any cash to convert his Bullish (BLSH) incentive units?

No cash payment is required when Thomas Farley converts his incentive units into Bullish Ordinary Shares. The footnote states that no consideration is payable upon conversion, so shares are issued without an additional purchase price upon vesting.

What type of security does Thomas Farley hold related to Bullish (BLSH)?

Thomas Farley holds Incentive Units in BMC1, a Bullish subsidiary. These derivative awards are exchangeable into Bullish Ordinary Shares, providing equity exposure through a vesting and performance-based structure rather than direct share purchases.