Grayscale has filed an amended S-1 in its latest move to convert its closed-end Dogecoin trust into an exchange-traded fund.
According to the filing with the U.S. Securities and Exchange Commission on Friday, the asset manager will tap Coinbase as a prime broker and custodian for the DOGE ETF, which would trade on NYSE Arca under the ticker GDOG, if approved. NYSE Arca previously filed a form to trade the Grayscale Dogecoin Trust.
Likewise, on Friday, NYSE Arca submitted a proposal to amend the Grayscale Ethereum Trust ETF and its "mini" version to trade under recently approved "generic listing standards," which come with less strict SEC oversight.
These updated forms come amid a flurry of activity in the crypto ETF space. Most notably on Wednesday, the SEC approved standards for listing crypto funds to simplify and shorten the process, a move that some experts say could open the floodgates to exchange-traded crypto products in the coming months.
It also comes in the wake of REX and Osprey receiving SEC approval to list their DOJE fund, the first U.S. fund tracking the price of the largest memecoin, on Thursday, as well as the official launch of Grayscale’s multi-asset crypto index fund tracking the leading digital assets BTC, ETH, SOL, XRP, and ADA.
Updated listing standards
One of the SEC’s new ETF listing standards is that a digital asset should have a futures market on a regulated exchange, like Coinbase, for six months. Grayscale notes that Dogecoin futures and options trading already occur on exchanges in the U.S. regulated by the Commodity Futures Trading Commission.
Grayscale also argues that GDOG should not be treated as a registered investment company under the Investment Company Act of 1940, the rule used by Rex-Osprey for its Solana and Dogecoin products, "and is therefore not subject to regulation under the Investment Company Act."
"Furthermore, the Sponsor [Grayscale] believes that the Trust is not a commodity pool for purposes of the Commodity Exchange Act of 1936, as administered by the CFTC and that neither the Sponsor nor the Trustee is subject to regulation by the CFTC as a commodity pool operator or a commodity trading advisor," Grayscale adds.
The updated S-1 was signed by Chairman of the Board of Directors Barry Silbert alongside other board members and Grayscale Chief Financial Officer Edward McGee, pursuant to the Securities Act of 1933, a rule focused on securities issuances. An S-1 is a registration statement filed with the SEC by a company looking to launch an ETF to provide information about a fund’s structure, management, and investment strategy.
Notably, Grayscale does not appear to have current plans to permit in-kind creations and redemptions for GDOG, despite recent SEC guidance allowing authorized participants to trade shares for a fund’s underlying assets.
During the Biden administration, the SEC greenlighted spot bitcoin ETFs and later Ethereum ETFs following a pivotal court ruling after Grayscale fought to appeal an earlier denial.
