REX Shares says it’s making ready to checklist what it calls the primary US Dogecoin ETF, teasing the product on X whilst a number of spot DOGE ETF functions stay pending on the Securities and Exchange Commission. Via X, REX Shares wrote on Wednesday: “The REX-Osprey™ DOGE ETF, DOJE, is coming quickly! DOJE would be the first ETF to ship buyers publicity to the efficiency of the enduring memecoin, Dogecoin. From REX-Osprey™, the group behind $SSK, the primary SOL + Staking ETF.”
The product traces again to a January 21, 2025 SEC submitting for a collection of crypto funds below the ETF Opportunities Trust, which included a REX-Osprey DOGE ETF alongside BTC, ETH, SOL, XRP, BONK and TRUMP-token funds. In that registration, the DOGE fund’s mandate is express: it “seeks funding outcomes, earlier than charges and bills, that correspond to the efficiency of Dogecoin.”
Can REX-Osprey Launch Their Dogecoin ETF First?
The obvious paradox—how REX can “launch” a DOGE ETF whereas spot Dogecoin ETPs are nonetheless within the SEC queue—comes all the way down to construction. Most DOGE proposals on file are commodity-based grantor trusts or related automobiles that require an alternate rule change below the Securities Exchange Act (a so-called 19b-4) earlier than they will checklist.
Bitwise, for instance, filed to checklist a Dogecoin ETF on NYSE Arca by means of that pathway, and Nasdaq has a pending proposal to checklist the 21Shares Dogecoin ETF. By distinction, REX’s DOGE product sits inside a 1940-Act open-end ETF belief, which registers below the Investment Company Act through a post-effective modification (Form 485(a)) and, if the registration goes efficient and an alternate accepts the itemizing below its generic ETF requirements, can come to market with out ready on a bespoke 19b-4 order.
That is identical playbook REX and Osprey used to carry their Solana + Staking ETF to market in July. Basically, the construction is much like how futures ETFs work.
The January prospectus additionally explains how publicity works. The DOGE fund will make investments “a minimum of 80%” of belongings in Dogecoin or devices offering DOGE publicity and should use “derivatives,” together with futures and swaps. Like REX-Osprey’s different single-coin funds, it depends on an entirely owned Cayman subsidiary—the “REX-Osprey DOGE (Cayman) Portfolio S.P.”—to carry sure positions; the dad or mum ETF’s funding in that sub is capped at 25% of whole belongings to protect regulated funding firm (RIC) tax remedy.
In plain phrases, it’s a ‘40-Act ETF that goals to reflect DOGE’s value, utilizing a mixture of direct publicity (together with through the Cayman sub) and, the place obtainable, derivatives.
Meanwhile, the “conventional” spot DOGE race is lively however unresolved. NYSE Arca’s submitting for a Bitwise Dogecoin ETF and Nasdaq’s proposal for a 21Shares Dogecoin ETF are each on the general public docket, and Grayscale submitted an S-1 to checklist a Dogecoin fund in mid-August. Those merchandise could be commodity ETPs requiring an alternate rule change earlier than buying and selling can start—therefore the longer timeline.
Notably, there’s additionally a transparent precedent for REX discovering a regulatory area of interest: on July 2, 2025, the REX-Osprey Solana + Staking ETF (ticker SSK) listed on Cboe as a ‘40-Act fund that passes by means of native staking rewards to shareholders. Cboe’s personal itemizing web page describes it succinctly: the fund seeks the efficiency of Solana “plus staking rewards related to the Reference Asset.”
REX’s launch heralded it as “the primary US-listed ETF to provide buyers publicity to Solana… plus staking rewards” in brokerage accounts. That was doable as a result of the belongings and mechanics match inside a ‘40-Act ETF framework augmented by a Cayman subsidiary and—in SSK’s early months—a C-corp tax wrapper that has since been transformed to RIC standing.
The parallels—up to a degree—are actual. REX is once more utilizing the ‘40-Act ETF chassis, the ETF Opportunities Trust umbrella and Cayman subs to pursue single-coin publicity with out ready for a brand new 19b-4 approval. But an vital distinction is technical and conclusive: Dogecoin is a proof-of-work cryptocurrency (merged-mined with Litecoin), so there isn’t any native staking yield to move by means of.
As for timing and standing, REX’s X put up is a teaser, not a discover of effectiveness. The January 21 submitting is a subject-to-completion prospectus; the SEC should permit the registration to go efficient, and an alternate should settle for the itemizing.
Separately, the SEC can also be weighing “generic” itemizing requirements for commodity- and crypto-based ETPs—guidelines that, if adopted, may streamline new crypto listings usually—although these proposals are unbiased of REX’s ‘40-Act path. In quick, REX can plausibly be first exactly as a result of it isn’t ready on a DOGE-specific 19b-4 approval, however the fund nonetheless wants its registration to clear and a list venue to put up a buying and selling date.
At press time, DOGE traded at $0.2165.
Featured picture created with DALL.E, chart from TradingView.com
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