The cryptocurrency market may be on the cusp of a significant development with the potential launch of the first Dogecoin (DOGE) exchange-traded fund (ETF) in the United States. According to Bloomberg ETF analyst Eric Balchunas, REX Shares, a prominent ETF issuer, has filed an effective prospectus with the U.S. Securities and Exchange Commission (SEC) for a Dogecoin ETF, with a possible launch as early as next week. This filing leverages the Investment Company Act of 1940, commonly referred to as the “40 Act,” a regulatory pathway that could expedite the fund’s market entry. This article explores the implications of this development, the regulatory strategy behind it, Dogecoin’s market dynamics, and the broader context of cryptocurrency ETFs in the U.S. financial landscape.
The REX Shares Dogecoin ETF: A Groundbreaking Proposal
REX Shares, in collaboration with Osprey Funds, has proposed the REX-Osprey DOGE ETF, which would trade under the ticker symbol DOJE. This fund aims to provide investors with direct exposure to Dogecoin’s price movements through a regulated investment vehicle. Unlike traditional crypto ETFs that require extensive SEC review through Form S-1 and Form 19b-4 filings, REX Shares is utilizing the 40 Act structure, a strategy previously employed for its Solana staking ETF ($SSK) launched earlier in 2025. This approach, described by ETF Store President Nate Geraci as a “regulatory end-around,” allows the fund to bypass some of the delays associated with traditional crypto ETF approvals.
The prospectus filed with the SEC highlights that the DOGE ETF will seek to mirror Dogecoin’s price performance, primarily through investments in a Cayman Islands subsidiary, the REX-Osprey DOGE (Cayman) Portfolio S.P. This subsidiary will hold DOGE tokens or derivatives to replicate the cryptocurrency’s price movements, ensuring compliance with U.S. regulations while avoiding complex tax reporting requirements like K-1 forms. The filing also acknowledges Dogecoin’s volatile nature, warning investors of “unique and substantial risks” due to rapid price swings and market uncertainty.
The 40 Act Pathway: A Strategic Advantage
The Investment Company Act of 1940 provides a framework for registered investment companies, including mutual funds and ETFs, offering stronger investor protections compared to other structures like the Securities Act of 1933. The 40 Act imposes stricter oversight, limits leverage and short-selling, and enforces robust fiduciary governance. By structuring the DOGE ETF under this act, REX Shares can potentially bring the fund to market more quickly than competitors pursuing the traditional S-1 and 19b-4 route. This strategy mirrors the successful launch of the REX-Osprey Solana + Staking ETF in July 2025, which also utilized a 40 Act structure to offer exposure to Solana’s price and staking rewards.
In contrast, other asset managers like Bitwise, Grayscale, and 21Shares have filed for Dogecoin ETFs under the Securities Act of 1933, which typically involves a lengthier SEC review process. For instance, Bitwise’s filing on January 28, 2025, and Grayscale’s filing in March 2025 are still pending SEC decisions, with deadlines extending into late 2025 or early 2026. The 40 Act pathway, therefore, positions REX Shares to potentially capture the first-mover advantage in the Dogecoin ETF market.
Dogecoin’s Market Dynamics and Cultural Significance
Dogecoin, originally created in 2013 as a lighthearted alternative to Bitcoin, has evolved into a cultural phenomenon and the world’s largest memecoin by market capitalization. As of September 5, 2025, DOGE trades at approximately $0.2129, reflecting a 116.67% increase over the past year but a 54% decline from its 2024 peak of $0.4672 in December, according to CoinMarketCap. With a market cap of around $23.24 billion, Dogecoin ranks as the eighth-largest cryptocurrency, underscoring its significant presence in the digital asset space.
The memecoin’s mainstream appeal is bolstered by high-profile endorsements, notably from billionaire Elon Musk, who has referred to himself as the “Dogefather.” Musk’s influence, including his 2021 comment on Saturday Night Live calling Dogecoin “a hustle,” has contributed to its volatility and visibility. More recently, reports indicate that Musk’s attorney, Alex Spiro, is chairing a $200 million public company focused on Dogecoin investments, further signaling institutional interest in the asset. This cultural and financial momentum makes Dogecoin an attractive candidate for an ETF, as it bridges the gap between retail enthusiasm and institutional investment.
Competitive Landscape and Regulatory Context
The race to launch a Dogecoin ETF is intensifying, with multiple asset managers vying for SEC approval. Bitwise, Grayscale, and 21Shares have all submitted applications, but their proposals face longer review timelines due to the traditional regulatory process. For example, 21Shares filed an S-1 registration on April 9, 2025, partnering with the Dogecoin Foundation’s corporate arm, House of Doge, to support its ETF. The SEC acknowledged this filing in May 2025, with a decision deadline potentially extending to January 9, 2026. Similarly, Grayscale’s filing in March 2025 and Bitwise’s in January 2025 are under review, with analysts estimating a 63% to 75% chance of approval by late 2025.
The SEC’s approach to crypto ETFs has evolved under new leadership. Following the resignation of former SEC Chair Gary Gensler in early 2025, Acting Chair Mark Uyeda and incoming Chair Paul Atkins have signaled a more crypto-friendly stance. The agency’s dismissal of cases against crypto firms and its engagement with industry stakeholders suggest a softening regulatory outlook, which could benefit Dogecoin ETF applications. Additionally, the SEC is reviewing proposals for “generic” listing standards for crypto-based ETFs, which, if adopted, could streamline future approvals. However, the agency’s fiduciary responsibility ensures that approvals will not be granted lightly, particularly for assets like Dogecoin, which lack a futures-based trading history on U.S. exchanges.
Potential Market Impact
The launch of a Dogecoin ETF could have profound implications for the cryptocurrency’s price and adoption. Analysts speculate that if Dogecoin ETFs capture even a fraction of the capital inflows seen by Bitcoin ETFs, the impact on DOGE’s market cap could be substantial. For instance, The Crypto Basic estimates that if Dogecoin ETFs secure 25% to 40% of Bitcoin ETF inflows (approximately $8.85 billion to $14.16 billion), DOGE’s market cap could increase by $1.044 trillion to $1.067 trillion, translating to a price range of $7.1 to $11.41 per token. Crypto analyst Ali Martinez has even predicted a potential rise to $15, based on historical price patterns within an ascending channel. While these projections are speculative, they highlight the potential for significant price appreciation driven by institutional investment.
However, Dogecoin’s volatility and lack of fundamental use cases compared to cryptocurrencies like Bitcoin or Ethereum pose risks. The SEC’s acknowledgment of these risks in REX Shares’ prospectus underscores the speculative nature of DOGE investments. Unlike the REX-Osprey Solana ETF, which benefits from staking yields, Dogecoin’s proof-of-work structure offers no such passive income, potentially limiting its appeal to yield-seeking investors.
Broader Implications for the Crypto ETF Market
The REX-Osprey DOGE ETF is part of a broader wave of cryptocurrency ETF filings, with REX Shares also proposing funds tied to Bitcoin, Ethereum, Solana, XRP, BONK, and the OFFICIAL TRUMP (TRUMP) token. This flurry of activity reflects growing institutional interest in digital assets, spurred by the SEC’s approval of 11 spot Bitcoin ETFs in January 2024 and subsequent Ethereum ETF approvals. Bloomberg Intelligence reports that the SEC is currently reviewing 92 crypto ETF applications, with decisions on Solana, XRP, and Litecoin funds expected by October 2025. The success of REX Shares’ 40 Act strategy could set a precedent for other issuers, potentially accelerating the introduction of niche crypto ETFs.
Conclusion
The potential launch of the REX-Osprey DOGE ETF marks a pivotal moment for Dogecoin and the broader cryptocurrency market. By leveraging the 40 Act pathway, REX Shares is poised to bring the first U.S.-listed Dogecoin ETF to market, potentially outpacing competitors like Bitwise, Grayscale, and 21Shares. Dogecoin’s cultural significance, coupled with its substantial market cap and institutional backing, makes it a compelling candidate for an ETF, despite its volatility and speculative nature. If approved, the DOJE ETF could drive significant capital inflows, enhance mainstream adoption, and reshape the landscape of cryptocurrency investment. However, investors must remain mindful of the risks outlined in the prospectus, as Dogecoin’s price remains subject to rapid swings and market uncertainty. As the SEC continues to navigate the evolving crypto ETF landscape, the outcome of this filing will be closely watched by investors and industry stakeholders alike.
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