
On 26 September 2025, the United States Securities and Exchange Commission (United States SEC) published [Release No. 34-104101; File No. SR-NYSEARCA-2025-73] titled “Notice of Filing and Immediate Effectiveness of Proposed Rule Change Relating to the Listing and Trading of Shares of the 7RCC Spot Bitcoin and Carbon Credit Futures ETF.” The notice states that NYSE Arca, Inc. filed the proposal under Section 19(b)(1) of the United States Securities Exchange Act of 1934 and United States SEC Rule 19b-4. The filing transitions the 7RCC Spot Bitcoin and Carbon Credit Futures ETF from its earlier authorisation under Rule 8.500-E (Trust Units) to the generic listing provisions of Rule 8.201-E (Generic). With the United States SEC granting immediate effectiveness, the ETF may now be listed and traded under the streamlined generic framework, reinforcing standardisation of crypto-linked and carbon-linked exchange-traded products in the United States.
The filing outlines the Exchange’s proposal to amend the listing status of the 7RCC Spot Bitcoin and Carbon Credit Futures ETF. Initially, the fund was approved for listing under Rule 8.500-E, which governs Trust Units composed of futures contracts and commodities. The approval was granted on 15 November 2024 through the “Original Approval Order” (Release No. 101641). However, the shares of the ETF were not listed or traded under that framework. On 17 September 2025, the United States SEC introduced Rule 8.201-E (Generic), permitting commodity-based trust shares to be listed without requiring separate Commission approval. The Exchange now proposes to rely on this generic rule to list and trade the ETF.
The filing states:
“The Exchange proposes to now list and trade the Shares of the Fund pursuant to the generic listing standards set forth in Rule 8.201-E (Generic), which would permit the Fund to operate in reliance on the generic listing standards in Rule 8.201-E (Generic) instead of the terms of the Original Approval Order.”
Purpose and Statutory Basis
The Exchange explains that the proposed change is consistent with Section 6(b) of the United States Securities Exchange Act of 1934, particularly Section 6(b)(5). According to the filing:
“The Exchange believes the proposed rule change is designed to remove impediments to and perfect the mechanism of a free and open market and, in general, to protect investors and the public interest because it would allow the Fund to be listed and traded under Rule 8.201-E (Generic) instead of Rule 8.500-E.”
This transition shifts the ETF into a framework designed to promote fairness, cooperation, and competition among exchange-traded products, while eliminating the need for reliance on one-off approval orders.
Timeline of the Decision
The regulatory pathway for the 7RCC ETF reflects the shift in United States ETF governance from case to case basis approvals to generic provisions. On 15 November 2024, the United States SEC approved the ETF under Rule 8.500-E (Trust Units), but shares did not list or trade. On 17 September 2025, the Commission introduced Rule 8.201-E (Generic) through Release No. 103995, creating a standardised compliance framework. On 25 September 2025, NYSE Arca, Inc. filed the proposed rule change with the United States SEC to reclassify the ETF under the new rule. On 26 September 2025, the Commission acknowledged the filing and granted immediate effectiveness, waiving the normal 30-day operative delay. From that date, the ETF is governed by Rule 8.201-E (Generic) and subject to its continued listing requirements.
Compliance for Crypto ETFs in USA
The adoption of generic provisions under Rule 8.201-E means issuers of crypto-based ETFs must ensure they satisfy standardised eligibility and disclosure conditions, both at the time of listing and throughout trading. Unlike the earlier non-generic system, issuers no longer require individual approval orders but must demonstrate compliance with:
- Uniform listing requirements for commodity-based trust shares.
- Ongoing obligations for transparency, disclosures, and continued listing.
- Alignment with Section 6(b)(5), ensuring protection of investors and prevention of manipulative practices.
Future applicants, whether offering Bitcoin, Ethereum, or hybrid products such as carbon-credit linked ETFs, will need to follow the same compliance route.
(Source: https://www.sec.gov/files/rules/sro/nysearca/2025/34-104101.pdf)