Comprehensive Analysis of the Upcoming US Spot Dogecoin ETF
In a major development for the cryptocurrency market, Bitwise Asset Management is poised to launch the first US spot Dogecoin ETF, potentially going live as early as Tuesday, November 26. This advancement follows the invocation of Section 8(a) of the Securities Act, which allows a registration statement to automatically take effect in 20 days unless the Securities and Exchange Commission (SEC) decides to intervene.
Bloomberg’s senior ETF analyst, Eric Balchunas, highlighted this strategic move, stating, “It appears Bitwise is employing the 8(a) strategy for their spot Dogecoin ETF, indicating their plan to go effective in 20 days unless an intervention occurs.”
Understanding the Mechanics of Section 8(a)
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The legal foundation of this maneuver lies in the provisions of Section 8(a). When an issuer omits the typical “delaying amendment” language from its S-1 registration and notes effectiveness “in accordance with Section 8(a),” the document is set to become effective autonomously after 20 days—unless the SEC intervenes to halt, postpone, or demand further amendments.
Recent SEC Policy Shifts and Their Impact
The context is crucial. In September, the SEC adopted new generic listing standards that simplified the process for spot digital-asset ETFs on major exchanges, replacing the previous case-by-case 19b-4 framework and reducing timelines. This policy shift has encouraged issuers to increasingly utilize Section 8(a) to become effective without an explicit “green light” order. This trend was particularly evident during October’s government shutdown, when several non-BTC/ETH crypto ETFs launched by simply removing their delaying amendments.
October Launches Set the Stage
The October precedents underscore Dogecoin’s timeline. For instance, on October 28, Bitwise’s Solana Staking ETF (ticker: BSOL) began trading on the NYSE, offering investors direct 100% SOL exposure with staking benefits. It quickly established primary and secondary market flow, becoming the benchmark for US SOL exposure.
Similarly, Canary Capital introduced a spot Hedera product on Nasdaq under the ticker HBR, providing regulated access to HBAR and proving that smaller-cap networks could meet operational requirements right from the outset.
These launches occurred while the SEC’s capacity was limited, precisely because issuers had omitted delaying amendments, allowing their S-1s to become effective after 20 days. Balchunas’s observation on Dogecoin—“plan to go effective in 20 days barring an intervention”—mirrors how these October debuts unfolded. No dramatic, customized approval order was needed; instead, the timeframe simply elapsed under Section 8(a), and trading commenced when the period concluded without SEC objection.
Implications of the Anticipated Launch Date
The prospective calendar date is significant: as Bitwise eliminated its delaying amendment on November 6, the statutory countdown indicates effectiveness around Tuesday, November 26, assuming the SEC does not intervene with a stop order or request further amendments, contingent on the resolution of the US government shutdown.
As of the latest data, DOGE is trading at $0.164 and remains above the 200-week EMA, as observed in the 1-week chart.
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