The U.S. Securities and Exchange Commission on February 13, 2025 published two NYSE Arca rule-filing notices that put proposed Grayscale exchange-traded products holding XRP and Dogecoin into the agency’s formal public-comment process. The documents did not approve either product. They established an administrative record in which the exchange had to show that listing the shares would comply with the Exchange Act.
That distinction mattered. Accepting and publishing a self-regulatory-organization filing is a procedural step, not a finding that the underlying asset is a security or commodity, not an endorsement of the trust, and not permission for shares to begin trading. Even so, the paired notices showed that the regulated-product pipeline was moving beyond bitcoin and ether toward assets with sharply different market histories and institutional profiles.
What the SEC notices did
Release 34-102420 covered NYSE Arca’s proposal to list and trade shares of the Grayscale XRP Trust under Rule 8.201-E for Commodity-Based Trust Shares. The SEC record says NYSE Arca submitted the original proposal on January 30, 2025 and a replacement amendment on February 10, 2025. Release 34-102416 covered the corresponding Grayscale Dogecoin Trust proposal, originally filed on January 31 and also replaced by an amendment on February 10.
In each case, the Commission said it was publishing the notice to solicit comments. After Federal Register publication, the Exchange Act process allowed the SEC 45 days to approve, disapprove or begin proceedings to determine whether to disapprove, subject to an extension of as much as 90 days. Those were review clocks, not expected launch dates.
The notices therefore verified three things as of February 13: NYSE Arca had made the proposals, amended versions were before the Commission, and public review was opening. They did not verify that the products would satisfy the statutory standard.
What the exchange proposed
NYSE Arca described both vehicles as trusts whose shares would represent proportional interests in their crypto holdings, less expenses and liabilities. For the XRP vehicle, the filing said the trust held only XRP and had approximately $16.1 million in assets under management as of January 22, 2025. It proposed daily valuation using the CoinDesk XRP Price Index at 4:00 p.m. New York time.
For the Dogecoin vehicle, the filing said the trust held only DOGE, expected the shares to use the ticker GDOG, and proposed valuation through the CoinDesk Dogecoin Price Index at 4:00 p.m. New York time. Coinbase Custody Trust Company was identified as custodian in both proposals, while BNY Mellon Asset Servicing was expected to serve as administrator and transfer agent.
Those product descriptions and operational assurances were statements in NYSE Arca’s filings. They should not be read as independent SEC conclusions.
Why the pairing mattered
The SEC had approved rules for spot bitcoin ETPs on January 10, 2024 and spot ether ETPs on May 23, 2024. The February 13, 2025 notices tested whether the exchange-listing framework could stretch further: XRP carried unresolved legal and market-structure questions, while Dogecoin began as a meme-oriented cryptocurrency and lacked bitcoin’s institutional history.
NYSE Arca argued that composite indices, public pricing, exchange surveillance, trading halts and information-sharing arrangements could help deter or detect manipulation. The central institutional question was whether those safeguards met the Exchange Act requirement that exchange rules prevent fraudulent and manipulative acts and protect investors and the public interest.
What remained uncertain
No shares were authorized to trade by the February 13 notices. The SEC had not resolved the legal characterization of XRP or DOGE through these documents, and publication did not guarantee approval. The record supported a narrower conclusion: two unconventional spot-crypto product proposals had advanced from private filing into transparent regulatory review, widening the boundary the U.S. market was being asked to consider.
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This article provides news and analysis, not investment, legal or tax advice. Digital assets are volatile and may result in total loss.

