The US Securities and Exchange Commission (SEC) has pushed back its decision on whether NYSE Arca can list the Bitwise Dogecoin ETF, designating a “longer period” to complete its review of the exchange’s proposed rule change under Rule 19b-4.
In a notice dated Sept. 9, the agency said it is extending the deadline to Nov. 12, 2025, to either approve or disapprove the application to list Bitwise’s DOGE trust as Commodity-Based Trust Shares under NYSE Arca Rule 8.201-E. “The Commission… designates November 12, 2025, as the date by which the Commission shall either approve or disapprove the proposed rule change,” the order states.
Spot Dogecoin ETF—Nah, But DOJE Is Coming
The delay keeps Bitwise in the growing queue of spot altcoin ETFs waiting on the traditional pathway used by the spot bitcoin and ether products: an exchange rule change under the Securities Exchange Act of 1934 paired with a Securities Act registration statement. Bitwise’s DOGE product is structured as a commodity-based trust that would hold Dogecoin in custody, with Coinbase Custody listed as the Dogecoin custodian in its S-1 filing.
Even as the spot DOGE application slips to November, a Dogecoin ETF from REX Shares and Osprey Funds is slated to begin trading this Thursday via a different regulatory route. The product will list under the ticker DOJE and is distributed by Foreside Fund Services, with launch timing confirmed for Thursday. This fund leverages the Investment Company Act of 1940—rather than the ’33/’34 Act spot-commodity-trust pathway—to offer DOGE exposure, a structure the issuers previously used for their Solana product.
Bloomberg’s Eric Balchunas framed the moment succinctly, posting on X: “Meme coin ETF era about to kick off it looks like with DOJE slated for a Thursday launch, albeit under the 40 Act a la SSK. There’s a big group of ‘33 Act-ers waiting for SEC approval still. Pretty sure this is first-ever US ETF to hold something that has no utility on purpose.”
REX-Osprey’s use of the ’40 Act route echoes the playbook behind SSK, the REX-Osprey SOL + Staking ETF, which lists on Cboe and holds SOL exposure while seeking to pass through staking rewards within the constraints of a registered fund. That earlier launch established a template for crypto-exposure ETFs that do not rely on an exchange’s 19b-4 rule change to list a spot commodity trust.
The SEC’s latest Bitwise order leaves the market with two parallel tracks for Dogecoin exposure in US ETFs. On one side is the Bitwise proposal, proceeding through the familiar spot-trust approval gauntlet that culminates on Nov. 12 absent another procedural shift. On the other is DOJE, which—if it begins trading Thursday—would represent a first-of-its-kind US DOGE ETF launched as a ’40 Act fund, a structure industry analysts say can reach the market without the same exchange rule-change approval required for commodity-based trusts.
For investors and issuers, the split underscores how crypto ETFs are evolving beyond the binary of “approved or denied” for spot commodity trusts. Bitwise is pursuing a product that would hold DOGE directly in a trust structure consistent with NYSE Arca’s Rule 8.201-E framework, while REX-Osprey appear set to offer DOGE exposure inside a registered investment company—akin to SSK’s approach—highlighting the growing role of ’40 Act mechanics in bringing non-bitcoin assets to the exchange-traded market.
At press time, DOGE traded at $0.24.
Featured image created with DALL.E, chart from TradingView.com
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