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US SEC Reviews NYSE Arca’s Proposal to List Bitwise Dogecoin ETF Under Commodity-Based Trust Shares Rule

On 11 March 2025, the US Securities and Exchange Commission (US SEC) published a notice detailing the proposed rule change submitted by NYSE Arca, Inc. (NYSE Arca) regarding the listing and trading of shares of the Bitwise Dogecoin ETF under NYSE Arca Rule 8.201-E, which governs Commodity-Based Trust Shares. The proposal, filed on 3 March 2025, is seeking permission and aims to establish a framework for trading an exchange-traded fund (ETF) that provides exposure to Dogecoin. The notice invites public comments on the proposed rule change before the US SEC considers its approval.

The NYSE Arca’s proposed rule change is to list and trade shares of the Bitwise Dogecoin ETF (the Trust), structured as a Delaware statutory trust. Bitwise Investment Advisers, LLC (Bitwise) will serve as the sponsor of the Trust, with Delaware Trust Company acting as the trustee. Custodial responsibilities for Dogecoin assets will be handled by Coinbase Custody Trust Company, LLC, while Bank of New York Mellon will serve as the Trust’s cash custodian, administrator, and transfer agent. The Trust will not be registered under the United States Investment Company Act of 1940, nor will it be classified as a commodity pool under the United States Commodity Exchange Act.

Investment objective of the Bitwise Dogecoin ETF is to provide investors with exposure to Dogecoin while minimising operational costs. The Trust will exclusively hold Dogecoin, maintaining only a small cash reserve for operational purposes, and will not engage in derivatives trading. The Net Asset Value (NAV) of the Trust will be determined daily based on the CF Dogecoin-Dollar Settlement Price (Pricing Benchmark) published by CF Benchmarks Ltd. The Trust will exclusively hold Dogecoin, with limited cash reserves for operational purposes, and will not engage in derivatives trading. The management fee will be accrued daily and paid in Dogecoin. NYSE Arca in its proposal states that the proposed ETF meets all applicable listing standards under its Rule 8.201-E and that the structure is designed to mitigate risks associated with fraud and market manipulation.

The US SEC has up to 45 days from the publication date in the Federal Register to approve, disapprove, or extend its review period by an additional 45 days if necessary. If the proposal is approved, the ETF would become one of the first exchange-traded products offering direct exposure to Dogecoin, potentially expanding investment opportunities within the cryptocurrency sector. The US SEC has invited public comments on the proposal, with submissions to be made via its online platform or through mail.

(Source: https://www.sec.gov/files/rules/sro/nysearca/2025/34-102570.pdf)