The product traces back to a January 21, 2025 SEC filing for a suite of crypto funds under the ETF Opportunities Trust, which included a REX-Osprey DOGE ETF alongside BTC, ETH, SOL, XRP, BONK and TRUMP-token funds. In that registration, the DOGE fund’s mandate is explicit: it “seeks investment results, before fees and expenses, that correspond to the performance of Dogecoin.”
The apparent paradox—how REX can “launch” a DOGE ETF while spot Dogecoin ETPs are still in the SEC queue—comes down to structure. Most DOGE proposals on file are commodity-based grantor trusts or similar vehicles that require an exchange rule change under the Securities Exchange Act (a so-called 19b-4) before they can list.
That is the same playbook REX and Osprey used to bring their Solana + Staking ETF to market in July. Basically, the structure is similar to how futures ETFs work.
The January prospectus also explains how exposure works. The DOGE fund will invest “at least 80%” of assets in Dogecoin or instruments providing DOGE exposure and may use “derivatives,” including futures and swaps. Like REX-Osprey’s other single-coin funds, it relies on a wholly owned Cayman subsidiary—the “REX-Osprey DOGE (Cayman) Portfolio S.P.”—to hold certain positions; the parent ETF’s investment in that sub is capped at 25% of total assets to preserve regulated investment company (RIC) tax treatment.
In plain terms, it’s a ‘40-Act ETF that aims to mirror DOGE’s price, using a mix of direct exposure (including via the Cayman sub) and, where available, derivatives.
Meanwhile, the “traditional” spot DOGE race is active but unresolved. NYSE Arca’s filing for a Bitwise Dogecoin ETF and Nasdaq’s proposal for a 21Shares Dogecoin ETF are both on the public docket, and Grayscale submitted an S-1 to list a Dogecoin fund in mid-August. Those products would be commodity ETPs requiring an exchange rule change before trading can begin—hence the longer timeline.
REX’s release heralded it as “the first US-listed ETF to give investors exposure to Solana… plus staking rewards” in brokerage accounts. That was possible because the assets and mechanics fit within a ‘40-Act ETF framework augmented by a Cayman subsidiary and—in SSK’s early months—a C-corp tax wrapper that has since been converted to RIC status.
The parallels—up to a point—are real. REX is again using the ‘40-Act ETF chassis, the ETF Opportunities Trust umbrella and Cayman subs to pursue single-coin exposure without waiting for a new 19b-4 approval. But an important difference is technical and conclusive: Dogecoin is a proof-of-work cryptocurrency (merged-mined with Litecoin), so there is no native staking yield to pass through.
Separately, the SEC is also weighing “generic” listing standards for commodity- and crypto-based ETPs—rules that, if adopted, could streamline new crypto listings generally—though those proposals are independent of REX’s ‘40-Act path. In short, REX can plausibly be first precisely because it isn’t waiting on a DOGE-specific 19b-4 approval, but the fund still needs its registration to clear and a listing venue to post a trading date.
At press time, DOGE traded at $0.2165.
