XRP & DOGE Spot ETFs: 100% Approval Odds Post-SEC Rule Change

The Dawn of a New Era for Spot Crypto ETFs

The landscape of cryptocurrency investment vehicles is undergoing a profound transformation, with leading financial analysts now declaring a near-certainty for the approval of spot Exchange-Traded Funds (ETFs) for digital assets like XRP and Dogecoin. This optimistic prognosis stems from a recent, pivotal regulatory shift by the U.S. Securities and Exchange Commission (SEC). Eric Balchunas, a senior ETF analyst at Bloomberg Intelligence, has boldly stated that the odds of these spot ETFs gaining U.S. approval have reached an unprecedented 100%. This assertion is grounded in the SEC's adoption of "generic listing standards," a rule change that significantly alters the previous approval paradigm, effectively rendering the traditional "approval clock" for 19b-4 filings obsolete. The focus has now squarely shifted to the final sign-off on S-1 registration statements from the SEC's Division of Corporation Finance, signaling that the last major hurdle is administrative rather than foundational.

Balchunas articulated this sentiment, noting, "Honestly the odds are really 100% now. Generic listing standards make the 19b-4s and their 'clock' meaningless. That just leaves the S-1s waiting for formal green light from Corp Finance." He further pointed to recent amendments filed by applicants for Solana ETFs as a strong indication that the process is in its terminal stages, humorously remarking that "The baby could come any day. Be ready." This atmosphere of impending change follows a series of developments initiated by the SEC's September 18 approval of generic listing standards for major exchanges such as NYSE Arca, Nasdaq, and Cboe. This landmark decision permits exchanges to list specific commodity-based ETPs—a category that now clearly encompasses qualifying crypto spot products—without the necessity of submitting an individual rule change under Exchange Act Section 19(b).

Unpacking the Regulatory Evolution: Generic Listing Standards

The essence of this regulatory overhaul lies in its streamlining effect. Historically, the approval of an ETF in the U.S. required a two-pronged approach. First, an exchange had to file a 19b-4 form, proposing a rule change to list a new product. This filing initiated a statutory clock, often fraught with extensions and delays, as the SEC deliberated on the suitability and market integrity concerns of the proposed product. Concurrently, the ETF issuer would file an S-1 registration statement, detailing the fund's structure, investment objectives, risks, and operational mechanics. The new generic listing standards (GLS) fundamentally alter the first part of this equation for commodity-based ETPs.

The Paradigm Shift from 19b-4 Filings to S-1 Registration

With the implementation of GLS, the protracted, deadline-driven 19b-4 process, which previously governed coin-by-coin approvals, is no longer a prerequisite for qualifying products. Instead, the remaining decisive element is the formal effectiveness of an issuer's S-1 registration statement. The SEC has framed this adjustment as an effort to transition commodity ETPs onto a more efficient and predictable approval pathway. Commissioner Hester Peirce, a long-standing advocate for a more permissive approach to crypto products, underscored this point, emphasizing that once an ETP conforms to the established generic standard, an exchange is empowered to list it without the need for prior 19(b) approval.

Streamlining the Approval Process

This shift represents a significant victory for proponents of spot crypto ETFs, as it removes a major bureaucratic hurdle that has historically been used by the SEC to delay or reject such products. By establishing clear, pre-defined standards, the regulatory body has created a more predictable environment for issuers. This move acknowledges the maturing nature of the digital asset market and signals a greater readiness on the part of regulators to integrate these assets into mainstream financial products, albeit under stringent guidelines. The focus on S-1 effectiveness means that the SEC's Division of Corporation Finance will primarily be assessing the completeness and accuracy of disclosure, rather than making broader policy judgments on the underlying asset's suitability for an ETF structure, a determination largely covered by the GLS.

Direct Implications for XRP and Dogecoin ETFs

The immediate catalyst for the renewed optimism surrounding XRP and DOGE specifically emerged from critical reporting by Eleanor Terrett. She disclosed that the SEC has actively requested issuers of proposed spot ETFs for a range of altcoins—including Litecoin, XRP, Solana, Cardano, and Dogecoin—to withdraw their pending 19b-4 filings. This request is a direct consequence of the "post-GLS" regime, where these forms are no longer deemed necessary. Terrett's initial post stated, "SCOOP: The SEC has asked issuers of LTC, XRP, SOL, ADA, and DOGE ETFs to withdraw their 19b-4 filings following the approval of the generic listing standards, which replace the need for those filings. Am told withdrawals could start happening as soon as this week."

Why Withdrawal of 19b-4s is a Positive Indicator

To address potential concerns, Terrett later clarified that such withdrawals are, in fact, a positive development. "More context for those asking whether withdrawal is a bad thing: the short answer is no… when the SEC approved the generic listing standards two weeks ago, it eliminated the need for exchanges to file 19b-4 forms to list individual token ETFs, simplifying and speeding up the process." This interpretation was swiftly endorsed by Balchunas, who commended Terrett's "nice scoop" and acknowledged that analysts had largely anticipated this shift once the generic standards were solidified. He reiterated, "This was something we thought could happen. It makes sense as you don't need 19b-4s in the post-GLS world. Just not sure how the launch schedule will work yet," indicating that the timing of launches is now predominantly a coordination issue between issuers and Corp Fin, rather than being dictated by a statutory countdown. This effectively removes a significant layer of regulatory friction, paving a clearer path for these digital asset products.

The Path Forward: S-1 Effectiveness and Market Anticipation

Tangible evidence that S-1 registration statements are indeed the primary remaining lever for approval is readily apparent in public filings. Recent days have seen multiple Solana spot ETF applicants, notably VanEck and 21Shares, submit fresh S-1/A amendments. For instance, VanEck's public docket displays "Amendment No. 4" filed just last week, with 21Shares likewise posting its fourth amendment. Such iterative amendments are characteristic of the end-game refinement typically observed before an S-1 is declared effective. While these specific updates pertain to Solana, the same filing and approval pathway will apply universally to any spot XRP or DOGE product seeking approval under the newly established generic listing standards. This synchronization of regulatory expectations across various crypto assets signifies a more standardized approach to their integration into traditional financial products.

Solana's Precedent: A Glimpse into the Final Stages

The advancements in the Solana ETF applications offer a valuable blueprint for what XRP and Dogecoin issuers can expect. The process of filing successive S-1/A amendments is a collaborative one, involving detailed feedback and adjustments between the issuers and the SEC's Corp Fin division. Each amendment addresses regulatory comments, refining disclosures, and ensuring all legal and operational requirements are met. This stage is crucial for ensuring investor protection and market transparency. Therefore, the observed progress with Solana suggests that the framework is robust and actively processing applications, providing a strong indicator of the final stages for other similar products.

Conclusion: A New Chapter for Crypto Investment Vehicles

While all these developments paint an overwhelmingly optimistic picture, it is crucial to recognize that they do not guarantee immediate launches or provide a definitive timetable. The central question now is not whether the SEC possesses the regulatory authority to approve such funds under its revised rules—it unequivocally does—but rather when Corp Fin will formally declare the S-1s effective, and how exchanges and issuers will orchestrate the initial listings under the nascent regime. The market eagerly awaits these final pronouncements, which will undoubtedly mark a significant milestone for XRP, Dogecoin, and the broader cryptocurrency investment landscape, ushering in a new era of regulated access to digital assets for institutional and retail investors alike.