Comprehensive Analysis of the SEC’s Decision Delay on Bitwise Dogecoin ETF
US SEC’s Prolonged Decision Timeline on Bitwise Dogecoin ETF
In a recent development, the United States Securities and Exchange Commission (SEC) announced an extension of its decision timeline regarding the listing of the Bitwise Dogecoin ETF on NYSE Arca. This postponement grants the SEC additional time to thoroughly evaluate the proposed rule change under Rule 19b-4. According to a notice issued on September 9, the deadline has been pushed to November 12, 2025. By this date, the SEC will make a definitive decision to either approve or reject the listing of Bitwise’s DOGE trust as Commodity-Based Trust Shares under NYSE Arca Rule 8.201-E.
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The Emergence of Spot Dogecoin ETF Alternatives
While the decision on Bitwise’s spot Dogecoin ETF remains pending, an alternative pathway has emerged. A Dogecoin ETF from REX Shares and Osprey Funds is set to commence trading under the ticker DOJE. Scheduled for a Thursday launch, this product takes a different regulatory approach by utilizing the Investment Company Act of 1940, rather than the conventional ’33/’34 Act spot-commodity-trust mechanism, to facilitate DOGE exposure. This innovative structure mirrors the strategy previously employed by REX and Osprey for their Solana product.
Industry Insights and Market Dynamics
Renowned Bloomberg analyst Eric Balchunas highlighted the significance of this development, commenting on the advent of the “Meme coin ETF era.” With the imminent launch of DOJE, the landscape for crypto ETFs is poised for transformation. The REX-Osprey strategy, reminiscent of their SOL + Staking ETF, exemplifies the potential of utilizing the ’40 Act route to list crypto-exposure ETFs, circumventing the need for an exchange’s 19b-4 rule change.
Exploring Parallel Tracks for Dogecoin Exposure
The SEC’s recent order regarding Bitwise leaves the market with two distinct pathways for Dogecoin exposure through US ETFs. On one hand, the Bitwise proposal continues its journey through the traditional spot-trust approval process, with a conclusive decision expected by November 12. On the other hand, DOJE, slated for trading this Thursday, represents an unprecedented US DOGE ETF launched as a ’40 Act fund. Industry experts suggest this structure avoids the exchange rule-change approval typically required for commodity-based trusts.
Implications for Investors and Issuers
This bifurcation highlights the evolving nature of crypto ETFs, moving beyond the binary of “approved or denied” for spot commodity trusts. Bitwise remains steadfast in its pursuit of a product that directly holds DOGE in a trust structure aligned with NYSE Arca’s Rule 8.201-E framework. Conversely, REX-Osprey’s approach aims to offer DOGE exposure within a registered investment company, akin to the SSK strategy. This development underscores the increasing significance of ’40 Act mechanics in facilitating the market entry of non-bitcoin assets.
Current Market Snapshot
As of the latest market data, DOGE is trading at $0.24, reflecting the dynamic nature of the cryptocurrency landscape.
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