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REX Shares is poised to launch what could be the first U.S.-listed
(DOGE) exchange-traded fund (ETF) as early as next week, according to Bloomberg ETF analyst Eric Balchunas. The move follows a regulatory strategy similar to the one used by for its staking ETF, which was listed under the Investment Company Act of 1940 (commonly referred to as the “40 Act”) [2]. This regulatory structure allows REX to bypass the traditional and often delayed SEC approval process required for spot crypto ETFs, which typically involve filing Form S-1 and Form 19b-4 [1].The 40 Act route has been described by ETF Store president Nate Geraci as a “regulatory end-around,” enabling faster market entry and reducing the likelihood of regulatory roadblocks [1]. REX’s filing for the
ETF highlights the inherent risks associated with the asset, noting that Dogecoin is a “relatively new innovation” and subject to “rapid price swings, changes, and uncertainty.” Over the past year, DOGE has surged 116.67%, according to CoinMarketCap, though it has since declined from its peak of $0.4672 in December to $0.2129 at the time of reporting [1].The DOGE ETF, once launched, will aim to track the performance of the meme coin by holding at least 80% of its assets in Dogecoin or instruments tied to DOGE exposure. The fund will also have the flexibility to utilize derivatives such as futures and swaps [3]. The structure is similar to how futures-based ETFs operate, with exposure managed through a Cayman-based subsidiary. This model mirrors the REX-Osprey Solana + Staking ETF (ticker SSK), which launched in July using a 40 Act structure. The Solana ETF includes native staking rewards passed to shareholders, though Dogecoin, being a proof-of-work cryptocurrency, does not offer a similar yield [3].
The market for Dogecoin continues to benefit from its unique cultural appeal, largely driven by its association with figures such as Elon Musk, who famously referred to the token as “a hustle” during a 2021 appearance on Saturday Night Live. More recently, Musk’s attorney, Alex Spiro, was reported to be spearheading a public company aiming to raise $200 million for Dogecoin investments, further highlighting the token’s mainstream traction [1]. Institutional interest has also been growing, with multiple traditional spot DOGE ETF applications still pending SEC approval. Firms such as Bitwise, Grayscale, and 21Shares have all submitted proposals, though they are currently waiting for the necessary regulatory clearances [1].
If approved, REX’s DOGE ETF would represent a significant milestone for the meme coin, which began as a joke but has since evolved into a cultural and financial phenomenon. The fund’s potential launch underscores the increasing institutional acceptance of alternative crypto assets and the regulatory adaptability of ETF providers in navigating the evolving landscape. The broader market remains watchful, as the SEC reviews a total of 92 crypto ETF applications, according to Bloomberg Intelligence analyst James Seyffart [1]. The success of the DOGE ETF could set a precedent for similar products and potentially trigger renewed interest in the token, especially given its historically volatile nature and high-profile backers.
Source:
[1] First Dogecoin ETF May Debut in the US Next Week (https://finance.yahoo.com/news/first-dogecoin-etf-may-debut-042810821.html)
[2] Dogecoin may see first-ever ETF launch next week: Analyst (https://cointelegraph.com/news/dogecoin-etf-united-states-launch-next-week-analyst)
[3] First Dogecoin ETF 'Coming Soon': REX-Osprey Teases... (https://www.mitrade.com/insights/news/live-news/article-3-1097444-20250905)

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