TLDR:
CBOE files ETF mixing PENGU tokens with Pudgy Penguins NFTs for SEC approval.
ETF allocates up to 95% to PENGU, 15% to NFTs, with no leverage or derivatives used.
SEC review underway; approval possible before March 1, per Bloomberg’s Eric Balchunas.
Canary Capital to handpick NFTs based on rarity, pricing, and visual appeal.
A new crypto-linked ETF may soon make history.
The CBOE has filed a 19b-4 form for the Canary PENGU ETF, a fund combining PENGU memecoins with Pudgy Penguins NFTs. This marks the first NFT-inclusive ETF to enter the SEC’s official review process. It follows a broader wave of digital asset filings that intensified after Donald Trump’s 2024 election win.
With this move, Canary Capital positions PENGU alongside traditional assets like BTC and SOL in the regulated investment space.
Canary PENGU ETF Mixes Tokens and NFTs
According to the filing, the ETF will allocate 80–95% of its assets to PENGU tokens and 5–15% to Pudgy Penguin NFTs. The structure offers traditional investors indirect access to both digital collectibles and memecoin-style assets.
Canary Capital will actively manage the portfolio, rebalancing it based on market trends and NFT desirability.
The PENGU token, issued on Solana, acts as a utility token tied to the Pudgy Penguins community. Although it lacks a dedicated use case, its link to the popular NFT project has driven community interest.
The fund may also hold small amounts of ETH and SOL, but only to support NFT and token transactions, not for investment.
Balchunas Hints at Early Launch Timeline for PENGU ETF
Bloomberg ETF analyst Eric Balchunas noted that the SEC review is now underway.
The Canary PENGU ETF, the first and only spot pudgy penguin filing, just got its 19b-4 filing via CBOE. On clock soon. pic.twitter.com/852jIPtuvF
— Eric Balchunas (@EricBalchunas) June 25, 2025
He stated that March 1, probably next year, is the deadline for approval, but earlier approval remains likely. The review falls in line with recent activity at the SEC, which is expected to outline standards for digital asset ETFs soon.
If approved, this would be the second memecoin-style ETF after DOGE and the first to include NFTs.
The ETF aims to make digital assets more accessible through regular brokerage accounts, removing direct custody risks for everyday investors. It avoids leverage, derivatives, or lending practices, offering a straightforward structure for crypto exposure.
NFT Selection Process and Risk Profile
Canary Capital will handpick which NFTs to include based on rarity, pricing, and visual traits.
However, the sponsor retains discretion to buy or sell NFTs at any time, depending on market activity. Given the speculative nature of memecoins and NFTs, the fund is categorized as high risk.
The SEC filing notes that shareholders will not receive direct benefits from holding PENGU or the NFTs.
By pushing the PENGU ETF into regulatory territory, Canary Capital opens the door for future NFT-backed investment products. If approved, it could become a landmark step in merging crypto culture with mainstream finance.
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