Bitwise Asset Management filed an updated registration statement this week that could allow a spot Dogecoin exchange-traded fund to begin trading by late November, assuming federal regulators decline to intervene during a mandatory review window. The firm removed a delaying amendment from its Securities and Exchange Commission filing, triggering an automatic effectiveness provision that would clear the product for launch on or around November 26, 2025, unless the agency acts to halt the process.
What to Know:
- The filing removes a delaying amendment, triggering an automatic 20-day countdown under Securities Act Section 8(a) provisions that could make the registration effective without explicit SEC approval
- Dogecoin would become the third cryptocurrency to gain spot ETF access in U.S. markets after Bitcoin and Ethereum, extending regulated exposure to meme-based digital assets
- The fund plans to hold actual Dogecoin tokens through Coinbase Custody Trust Company rather than derivatives contracts, with cash holdings stored at BNY Mellon
Regulatory Clock Starts Ticking
The procedural shift relies on a provision within Section 8(a) of the Securities Act that permits registrations to become effective automatically if the SEC does not object within 20 calendar days.
Bloomberg ETF analyst Eric Balchunas noted the amendment removal in a post on X, describing the approach as an "8(a) move" that puts the agency on a deadline to either approve or delay the product.
The 20-day window began when Bitwise submitted the revised S-1 filing earlier this week.
The mechanism does not guarantee launch. The SEC retains authority to request additional information, impose conditions or issue a formal delay during the countdown period. The agency has exercised that discretion in previous crypto ETF filings when staff identified outstanding disclosure concerns or market structure questions.
Fund Structure and Custodial Arrangements
The prospectus specifies that the ETF would hold actual Dogecoin tokens rather than futures contracts or other derivative instruments. Coinbase Custody Trust Company would store the digital assets, while Bank of New York Mellon would handle cash positions. The fund's net asset value would track the CF Dogecoin-Dollar Settlement Price, a benchmark used to determine daily valuations.
Bitwise plans to list the product on NYSE Arca, though the firm has not yet disclosed a ticker symbol or expense ratio.
The filing warns of standard cryptocurrency risks, including price volatility, liquidity constraints and regulatory uncertainty. No seed capital figures have been made public.
An effective registration statement represents one stage in the launch process. Exchange approval, market-maker commitments and final custodial agreements must also align before trading can commence. That sequence means an effective date may not immediately translate into public availability.
Market Implications and Remaining Hurdles
A Dogecoin ETF would expand the roster of spot cryptocurrency products available to U.S. investors beyond Bitcoin and Ethereum, the only two digital assets currently accessible through exchange-traded funds. The development reflects growing institutional interest in regulated vehicles for altcoin exposure, particularly as crypto markets have broadened beyond the two largest tokens by market capitalization.
Industry observers note that spot ETF launches have accelerated access to digital assets for investors who prefer traditional brokerage accounts over cryptocurrency exchanges.
Bitcoin spot ETFs attracted significant inflows following their January 2024 debuts, while Ethereum products launched in July 2024.
Dogecoin, originally created as a parody currency in 2013, has maintained a market capitalization exceeding $20 billion despite its origins as an internet meme.
The filing arrives during a period of heightened regulatory scrutiny of cryptocurrency products. The SEC has historically expressed caution about approving ETFs tied to assets outside Bitcoin and Ethereum, citing concerns about market manipulation and investor protection. Dogecoin's price history includes sharp swings driven by social media activity and celebrity endorsements, factors that regulators have previously identified as market stability risks.
Understanding Exchange-Traded Funds
Exchange-traded funds are investment vehicles that trade on stock exchanges like individual securities but hold baskets of underlying assets. A spot ETF directly owns the asset it tracks, unlike futures-based ETFs that hold derivative contracts. The structure allows investors to gain exposure to an asset's price movements without directly purchasing or storing it themselves. Custodians provide secure storage for physical or digital holdings, while authorized participants facilitate the creation and redemption of ETF shares to maintain price alignment with the underlying asset.
Closing Thoughts
Formal notices from the SEC or NYSE Arca regarding the registration's effective status should arrive before the November 26 deadline if the filing proceeds without intervention. Additional details including the expense ratio, ticker symbol and market-maker lineup would typically emerge in subsequent filings as the launch date approaches. The absence of SEC action during the 20-day window would clear the product for trading, though exact timing would depend on final exchange approval and operational readiness.