TLDR
- Bitwise submitted an S-1 filing with the SEC on January 28, 2025, for a spot Dogecoin ETF
- Rex Shares and Osprey Funds previously filed Form N1-A for multiple crypto ETFs including DOGE
- Bitwise filed under the “33 Act” while Rex and Osprey filed under the “40 Act” which has stricter oversight
- The filing follows Bitwise’s earlier Delaware registration on January 22
- A Dogecoin ETF would allow regulated exposure to DOGE without needing crypto wallets
The race to launch the first Dogecoin ETF intensified as Bitwise Asset Management formally submitted its S-1 registration with the Securities and Exchange Commission on January 28, 2025. This latest development marks a crucial step forward in bringing the popular meme cryptocurrency to traditional investment markets.
The S-1 filing represents Bitwise’s official declaration of intent to offer a spot Dogecoin exchange-traded fund, building upon their earlier groundwork laid through a Delaware registration on January 22. Bloomberg ETF analyst James Seyffart confirmed the anticipated filing through social media platform X, highlighting its importance in the formal SEC approval process.
NEW: @BitwiseInvest officially files an S-1 for the Bitwise Dogecoin ETF. pic.twitter.com/GT9JjU67CY
— James Seyffart (@JSeyff) January 28, 2025
Bitwise’s pursuit of a Dogecoin ETF isn’t happening in isolation. Just days earlier, on January 21, both Rex Shares and Osprey Funds filed their own registration forms for multiple cryptocurrency ETFs. Their ambitious proposals extend beyond Dogecoin to include other digital assets such as Official Trump (TRUMP), Solana (SOL), Bitcoin (BTC), and Ripple (XRP).
The regulatory approach chosen by these firms differs notably. Bitwise opted to file under the Securities Act of 1933, commonly known as the “33 Act,” which typically governs specialty ETFs and commodity-based products. Bloomberg ETF analyst Eric Balchunas pointed out this distinction to CoinDesk, noting its implications for the approval process.
In contrast, Rex Shares and Osprey Funds chose to file under the Investment Company Act of 1940, referred to as the “40 Act.” This regulatory framework imposes more rigorous SEC oversight and includes stricter governance requirements. The 40 Act also places firmer restrictions on potentially risky investment strategies such as leverage and short-selling.
For potential investors, a Dogecoin ETF would introduce several advantages. The structure would enable exposure to DOGE’s price movements within a regulated environment, eliminating the need for cryptocurrency wallets or direct interaction with crypto exchanges. This accessibility could attract traditional investors who have been hesitant to engage with cryptocurrency platforms.
The ETF format brings additional benefits, including enhanced liquidity for traders and improved cost efficiency in managing positions. The regulated nature of ETFs also provides greater transparency in pricing and trading volumes compared to direct cryptocurrency investments.
However, the path to approval faces several challenges. Meme cryptocurrencies like Dogecoin have faced ongoing scrutiny due to their price volatility and perceived lack of fundamental value. Legal expert Max Buwick of Burwick Law expressed concerns on January 16, characterizing meme coins as problematic investment vehicles that may exploit investor enthusiasm.
The timing of these filings coincides with broader changes in the cryptocurrency investment landscape. The CEO of CryptoQuant noted that former President Trump’s influence has ushered in a new era for meme coins, regardless of individual opinions on their merit as investments.
Following the Delaware registration, Bitwise moved quickly to formalize their SEC filing. The S-1 document outlines the specific structure and operation of their proposed Dogecoin ETF, though the exact details remain subject to regulatory review and potential modifications.
The multiple ETF applications suggest growing institutional interest in providing regulated access to Dogecoin investments. This development follows the broader trend of traditional finance embracing cryptocurrency products through regulated vehicles.
Market observers note that the approval process could face varying timelines depending on the chosen regulatory framework. The 40 Act applications by Rex Shares and Osprey might encounter more extensive review periods due to their stricter regulatory requirements.
The proposed ETFs would track Dogecoin’s market price through direct ownership of the cryptocurrency, storing the underlying assets with qualified custodians. This structure differs from futures-based products and aims to provide more direct price exposure.
Trading volumes and market interest in Dogecoin continue to influence the timing of these ETF proposals. The cryptocurrency’s large market capitalization and active trading community make it an attractive candidate for ETF development.
Recent data shows sustained institutional demand for cryptocurrency investment products, particularly following the approval of spot Bitcoin ETFs. This precedent may impact the review process for Dogecoin ETF applications.
Stock exchange listings for these proposed ETFs would be determined following SEC approval, with major exchanges likely to compete for listing rights. The trading infrastructure for cryptocurrency ETFs continues to evolve, building on lessons from existing products.
