A company specializing in cryptocurrency index funds has submitted an S-1 filing to the Securities and Exchange Commission (SEC) to obtain approval for an exchange-traded fund (ETF) linked to the performance of Dogecoin (DOGE). This submission follows closely after the establishment of a Dogecoin ETF trust within Delaware, indicating a strong interest in bringing this cryptocurrency into regulated investment structures.
For the ETF to be officially listed and traded on public exchanges, the SEC needs to review and approve two specific regulatory forms: the S-1 and the 19b-4. The S-1 is provided by the issuer and details important aspects of the product, while the 19b-4, submitted by the exchange on which the product will trade, delineates the conditions for listing and any necessary amendments to existing listing rules.
This is not the first initiative aimed at establishing a Dogecoin ETF, as other entities, including Rex Shares and Osprey Funds, have previously sought regulatory approval for various cryptocurrency ETFs. Notably, the S-1 submissions from these companies differ significantly from the current filing, as they followed the 40 Act, which imposes more stringent investor protections. In contrast, the current filing aims to establish a DOGE ETF under the 33 Act, which is typically associated with specialized, commodity-based ETFs.
The distinction between the two acts reflects a shift in how these investment products may be structured. Generally, the 40 Act includes provisions designed to safeguard investors, such as limitations on leverage and short-selling, as well as enhanced fiduciary oversight. On the other hand, the 33 Act filings typically provide a different approach to asset backing and regulatory requirements.
The landscape surrounding cryptocurrency ETFs in the United States is evolving. Historically, the SEC has been cautious in granting approvals, but a notable shift occurred in January 2024 when the SEC approved the simultaneous listing and trading of 11 Bitcoin ETFs. This change was further complemented by the subsequent approval of an Ethereum ETF, signaling a growing acceptance of cryptocurrency as a viable investment asset class.
Currently, the entity in question has already established itself as an issuer of ETFs focused on Bitcoin and Ethereum, and they are actively pursuing additional approvals for XRP and Solana ETFs alongside the proposed Dogecoin ETF.
The regulatory environment has been influenced by changes in leadership within the SEC. Gary Gensler, the former chair, had expressed skepticism toward cryptocurrencies, while the appointment of Mark Uyeda as Acting SEC Chair—following Donald Trump’s presidency—has opened pathways for more crypto-friendly policy considerations. The subsequent nomination of Paul Atkins is also anticipated to shape the future of cryptocurrency regulation and oversight in the United States.
In addition to these individual efforts, a working group was convened recently to delve into potential policies surrounding cryptocurrency, indicating a broader governmental interest in establishing clear frameworks for managing these emerging digital assets.
As the situation continues to develop, it remains to be seen how regulatory bodies will handle new filings and what impacts these decisions will have on the cryptocurrency market as a whole. The approval process not only affects the specific products being filed for but also reflects the ongoing dialogue about the legitimacy and future of cryptocurrency investment vehicles, particularly as they become integrated into more traditional financial frameworks.