On 10 June 2025, the United States Securities and Exchange Commission (US SEC) issued an order instituting proceedings to determine whether to approve or disapprove a proposed rule change submitted by The Nasdaq Stock Market LLC. The proposal seeks to list and trade shares of the Grayscale Polkadot Trust (DOT) under Nasdaq Rule 5711(d), which governs the listing of commodity-based trust shares. The order has been issued under file number SR-NASDAQ-2025-019.
The proposed rule change was initially filed on 24 February 2025, in accordance with Section 19(b)(1) of the United States Securities Exchange Act of 1934 and United States Rule 19b-4. It was published for comment in the Federal Register on 13 March 2025. On 24 April 2025, the US SEC extended its review period and has now formally commenced proceedings under Section 19(b)(2)(B) of the Act to further evaluate the rule change.
According to the filing, the Grayscale Polkadot Trust (DOT) is designed to reflect the value of the DOT tokens held by the Trust, less the Trust’s expenses and liabilities. The net asset value of the Trust would be based on the CoinDesk DOT CCIXber Reference Rate, which aggregates DOT trade data from multiple digital asset trading platforms. The Trust will hold only DOT and will permit creation and redemption of shares in blocks of 10,000, solely in cash. The sponsor of the Trust is Grayscale Investment Sponsors, LLC (as of 3 May 2025), with CSC Delaware Trust Company acting as trustee and Coinbase Custody Trust Company, LLC serving as custodian.
The institution of proceedings does not imply any final conclusion but enables additional consideration of whether the proposal complies with Section 6(b)(5) of the United States Securities Exchange Act of 1934. The US SEC specifically invited comments on whether the proposed listing of a DOT-based trust raises new or novel concerns, particularly regarding the resistance of DOT markets to fraud and manipulation, or whether sufficient market surveillance mechanisms are in place. Public comments referencing file number SR-NASDAQ-2025-019 may be submitted electronically or via mail.
(Source: https://www.sec.gov/files/rules/sro/nasdaq/2025/34-103218.pdf)
