Bloomberg Intelligence senior ETF analyst Eric Balchunas says the odds of spot ETFs for XRP and Dogecoin winning US approval are now 100%, arguing that last week’s rule change to adopt generic listing standards has rendered the old approval clock irrelevant and left only registration statements awaiting a final sign-off from the SEC’s Division of Corporation Finance.
“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 wrote, adding that applicants for Solana ETFs have already filed another round of amendments, a sign the process is in its final stages. “The baby could come any day. Be ready.”
Balchunas’ call follows a flurry of developments triggered by the SEC’s September 18 approval of “generic listing standards” at NYSE Arca, Nasdaq and Cboe. That decision allows exchanges to list certain commodity-based ETPs—including crypto spot products that meet the criteria—without submitting a separate rule change under Exchange Act Section 19(b).
In effect, the long, deadline-driven 19b-4 process that governed coin-by-coin approvals is no longer required for qualifying products; instead, the remaining gating item is the effectiveness of an issuer’s S-1 registration. The agency framed the change as bringing commodity ETPs onto a more streamlined path, while Commissioner Hester Peirce emphasized that, once an ETP fits the standard, an exchange can list it without prior 19(b) approval.
What This Means For Spot XRP And Dogecoin ETFs
The near-term catalyst for XRP and DOGE specifically emerged from reporting by Eleanor Terrett, who said the SEC has asked issuers of proposed spot ETFs for Litecoin, XRP, Solana, Cardano and Dogecoin to withdraw their pending 19b-4 filings because those forms are no longer needed in the “post-GLS” regime.
“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,” Terrett posted.
She later added, “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.”
Balchunas endorsed that interpretation, calling Terrett’s report a “nice scoop” and noting that analysts had anticipated this shift once generic standards were finalized. “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,” he wrote, suggesting timing is now primarily an issuer and Corp Fin coordination question rather than a statutory countdown.
Evidence that S-1s are indeed the remaining lever is visible on EDGAR. In recent days multiple Solana spot ETF applicants, including VanEck and 21Shares, submitted fresh S-1/A amendments—VanEck’s docket shows an “Amendment No. 4” filed late last week, while 21Shares likewise posted Amendment No. 4—consistent with the end-game polishing typical before effectiveness. While those updates are for Solana, the same filing pathway would apply to any spot XRP or DOGE product under the new standards.
However, none of this guarantees immediate launches or provides a definitive timetable. The operative question now is not whether the SEC can approve such funds under its own rules—it can—but when Corp Fin will declare the S-1s effective and how exchanges and issuers will choreograph first-day listings under the new regime.
At press time, XRP traded at $2.89.
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