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The Depository Trust and Clearing Corporation (DTCC) has listed 21Shares'
exchange-traded fund (TDOG), marking a procedural step toward potential U.S. market entry pending U.S. Securities and Exchange Commission (SEC) approval. The fund, structured as a physically backed trust, aims to hold Dogecoin (DOGE) directly and issue shares designed to track the cryptocurrency's price net of fees. TDOG calculates its daily net asset value (NAV) using a multi-exchange price index and publishes intraday indicative values every 15 seconds during market hours. However, the DTCC listing does not indicate regulatory clearance, as the ETF still requires formal approvals for its S-1 registration and Nasdaq's 19b-4 rule change.TDOG's operational mechanics involve cash-based creations and redemptions, with authorized participants delivering cash to the sponsor, who then instructs
to purchase DOGE. These coins are stored with Coinbase Custody Trust Company. Arbitrage activities by market makers and APs are expected to help align the share price with NAV, though intraday premiums or discounts may persist during periods of volatility. A key structural feature is the "pay in kind" fee model, where sponsor fees are deducted in DOGE, gradually reducing the amount of Dogecoin per share over time.The TDOG ETF would compete with the REX-Osprey DOGE ETF (DOJE), which launched on Cboe BZX in September 2025. DOJE, a 1940-Act ETF, holds a combination of spot DOGE and DOGE-linked instruments, including a Cayman-domiciled subsidiary to maintain tax compliance. In contrast, TDOG would operate as a commodity-based trust, with NAV derived from CF Benchmarks' once-daily Dogecoin-dollar settlement price. DOJE's expense ratio is 1.50%, while TDOG's sponsor fee remains undisclosed in preliminary filings. Both products offer U.S. investors regulated exposure to Dogecoin but differ in structure, fee profiles, and operational mechanisms.
The approval of TDOG would represent a significant milestone for Dogecoin, a cryptocurrency initially conceived as a joke in 2013 but now attracting institutional interest. The SEC's cautious approach to meme-based cryptocurrencies has delayed similar ETFs, though the recent approval of
and futures ETFs has created a regulatory precedent. Analysts note that TDOG's DTCC listing reflects growing institutional confidence in crypto assets, particularly altcoins, as diversified investment vehicles. However, the SEC's focus on investor protection and market manipulation risks remains a critical hurdle.If approved, TDOG would allow investors to access Dogecoin through traditional brokerage accounts without managing wallets or onchain utilities. This convenience comes with trade-offs, including the gradual erosion of DOGE holdings due to in-kind fee deductions and reliance on custodial services like Coinbase. Direct ownership of DOGE, by contrast, offers full onchain control but requires managing key security and exchange risks. The choice between TDOG and direct ownership hinges on investor priorities: institutional-grade infrastructure versus onchain flexibility.
The broader crypto ETF landscape is evolving, with over 70 applications under SEC review as of April 2025. Bitwise's recent amendments to its Dogecoin and
ETF proposals-adding in-kind redemptions-highlight the industry's adaptation to regulatory expectations. Bloomberg analyst Eric Balchunas estimates a 90% chance of approval for such products by October 2025. These developments underscore a shifting regulatory environment where innovation in crypto ETF structures may accelerate adoption of altcoins like Dogecoin.Source: [1] Cointelegraph (https://cointelegraph.com/explained/dogecoin-etf)
[2] Moneycheck (https://moneycheck.com/21shares-dogecoin-etf-tdog-listed-on-dtcc-awaiting-sec-approval/)
[3] The Block (https://www.theblock.co/post/371138/shell-first-us-dogecoin-etf-hits-the-market-using-unique-legal-structure)
[4] Ecoinimist (https://ecoinimist.com/2025/06/27/bitwise-amends-dogecoin-and-aptos-etfs/)

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