The U.S. government shutdown paves the way! XRP and DOGE ETFs can be listed without SEC approval, with a fee of about 0.35%.

Bitwise and Grayscale have revealed the fees for their proposed exchange-traded funds tracking the prices of XRP and DOGE, with both charging a rate of about 0.35%. According to informed sources, Grayscale plans to use the strategy from last week's SOL ETF launch when it introduces the XRP ETF, meaning that the fund may also be able to list without SEC approval.

Bitwise and Grayscale Fee Strategy Comparison

(Source: Grayscale)

Bitwise announced that it will charge a fee of 0.34% for its Bitwise XRP ETF, while Grayscale disclosed a rate of 0.35% in its respective documents. Grayscale's DOGE ETF also charges the same fee of 0.35%. This level of fees is considered moderately low in the crypto ETF market. For reference, BlackRock's IBIT (Bitcoin ETF) charges a fee of 0.25%, while Grayscale's GBTC previously charged up to 2% before converting to an ETF.

The small difference of 0.34% and 0.35% shows that Bitwise is trying to gain a competitive advantage in pricing. In the ETF market, a 0.01% fee difference seems negligible, but for large institutional investors, it can save hundreds of thousands of dollars annually on a scale of hundreds of millions of dollars in allocation. This pricing competition strategy is the norm in the ETF industry, usually initiated by smaller issuers attempting to capture market share from industry giants.

Grayscale has chosen a uniform fee rate of 0.35%, indicating that its pricing strategy is more simplified and standardized. Adopting the same fee rate for XRP and DOGE, two assets with different characteristics, may be aimed at reducing the management complexity of the product line. As a pioneer in cryptocurrency asset management, Grayscale has strong brand recognition and an institutional client base, and its fee strategy focuses more on brand premium rather than price competition.

The listing of these ETFs occurred after companies decided to adopt non-traditional methods to launch these products. Last week, Bitwise and Grayscale launched ETFs tracking the price of SOL, raising millions of dollars. Bitwise's SOL ETF raised $56 million on its first day of issuance, becoming the highest-grossing ETF launch of the year. This successful case provides important reference for the launch of XRP and DOGE ETFs.

Bitwise vs Grayscale Fee Comparison

Bitwise XRP ETF: 0.34% (price competitive)

Grayscale XRP ETF: 0.35% (standardized pricing)

Grayscale DOGE ETF: 0.35% (same as XRP)

Market Reference: BlackRock IBIT 0.25%, Grayscale GBTC once reached 2%

First Day Fundraising Reference: Bitwise SOL ETF raised 56 million USD on its first day.

Canary Capital also launched a fund tracking Litecoin and HBAR last week, indicating that this strategy of circumventing the traditional SEC approval process is being adopted by multiple asset management companies. This marks a new competitive phase for the crypto ETF market.

Regulatory vacuum created by the U.S. government shutdown

The U.S. government is about to face the longest shutdown in history, resulting in the SEC having only a small number of staff to maintain operations, limited to executing the shutdown plan. Many employees are forced to take leave, severely restricting their scope of work. Before the shutdown, the SEC approved listing standards, which means that dozens of cryptocurrency ETF applications can go live more quickly. This regulatory vacuum provides asset management companies with an unprecedented opportunity window.

On October 1, after a week of government shutdown, the SEC issued guidance clarifying the process for companies to go public. The SEC stated in the guidance that if a company wants to go public, it can directly submit an S-1 registration statement without the need to submit a so-called “delayed amendment.” A delayed amendment means that the ETF will take effect 20 days later to give the SEC time to address various opinions. This streamlined process would normally be impossible, but the government shutdown forced the SEC to adopt a more flexible policy.

The S-1 document must be finalized, and if any modifications are made, the effective period will be recalculated to 20 days. In addition, the assets of the ETF must also meet listing standards. All these factors combined mean that the company could potentially issue a cryptocurrency ETF without SEC approval. This “compliant but unapproved” gray area is a product of regulatory innovation, leveraging the flexibility of existing rules.

According to informed sources, Grayscale plans to launch an XRP ETF in the same manner as the SOL ETF launched last week, which means that its XRP ETF may be listed without the need for SEC approval. Grayscale's SOL ETF uses a “conversion” strategy, converting the existing Grayscale Solana Trust into an ETF, rather than submitting a brand new ETF application. This approach bypasses the traditional SEC approval process and utilizes special rules for converting trust products into ETFs. Bitwise has not commented on its listing strategy for the XRP ETF, but the industry generally expects a similar approach to be taken.

Market Expectations and Analyst Views

Nate Geraci, president of NovaDius Wealth Management, posted on X Forum on Sunday: “I expect the first spot XRP ETF to launch within the next two weeks. The SEC's lawsuit against Ripple has lasted five years and only concluded three months ago. In my view, the launch of the spot XRP ETF signifies a total failure of the previous anti-cryptocurrency regulatory agencies.” This comment carries strong political and symbolic significance.

The SEC's lawsuit against Ripple began in December 2020 and lasted nearly five years, ultimately reaching a settlement in July 2025. This lawsuit once led to XRP being delisted from several American exchanges, resulting in a significant decrease in its market value. Now, not only has the lawsuit been settled, but the XRP ETF is also set to launch, and this dramatic turnaround can indeed be seen as a victory for Ripple and a failure of the previous SEC policies.

From the market reaction, the expected launch of the XRP and DOGE ETFs has already been partly reflected in the prices. XRP surged to $3.65 after the lawsuit settlement, although it has currently retreated to around $2.3, it is still significantly up compared to a year ago. As the most popular meme coin, the launch of DOGE's ETF will provide a compliant investment channel for institutional investors for the first time, and is expected to trigger a similar inflow effect of institutional funds as seen with XRP.

However, investors also need to be aware of the risks. First, this method of listing “without SEC approval” still carries legal uncertainties; if the SEC later determines a violation, it may require delisting or rectification. Second, the volatility of XRP and DOGE far exceeds that of Bitcoin and Ethereum, and it remains to be seen whether institutional investors' risk appetite can accept this. Third, the actual demand for these ETFs has not yet been tested; although the Bitwise SOL ETF performed brilliantly on its first day, it is still unknown whether the subsequent capital inflow can continue.

Impact of Non-Traditional Paths on the Crypto ETF Market

This unconventional ETF listing path could permanently change the game rules of the crypto ETF market. Prior to this, the launch of crypto ETFs typically required a lengthy SEC approval process, with months or even years often needed from application submission to approval for listing. The application for a Bitcoin spot ETF began in 2013 and was not finally approved until 2024, taking over a decade. This lengthy process greatly limits the speed of product innovation.

Today, asset management companies can launch new ETFs within weeks by utilizing a combination strategy of listing standards and trust conversions. This will accelerate the diversification of products in the crypto ETF market, providing investors with richer choices. However, this acceleration may also bring risks. The traditional SEC approval process, although lengthy, provides ample time for regulators to review product designs, risk disclosures, and investor protection measures. Bypassing this process may allow certain flawed products to be listed, increasing risks for investors.

In the long term, the game of regulation versus innovation will continue to evolve. The SEC may tighten rules after the government reopens, closing current loopholes. Alternatively, regulators may realize that the existing approval processes are too rigid, thus formally adopting more flexible rules. Either way, the bold attempts by Bitwise and Grayscale have set a precedent for the industry, proving that there is indeed a legitimate path to accelerate product launches within the existing regulatory framework.