Geraci’s optimism rests in part on the composition of GDLC. As of June 27 the fund holds 80.8 percent Bitcoin and 11.1 percent Ether, while XRP, Solana and Cardano account for a combined 8.1 percent—well below the weights that have historically triggered regulatory push-back on liquidity or market-manipulation grounds. “XRP, SOL & ADA represent <10 % combined of GDLC’s holdings. Easy way to slowly step into other assets,” he wrote, framing the multi-token product as a low-risk sandbox for the agency.
Geraci argues that the Commission already has a template for limited non-traditional exposures. Since February the SEC has permitted up to 15 percent of an ETF’s portfolio to consist of illiquid private-credit instruments, provided sponsors can demonstrate robust valuation and liquidity controls. “No reason to not allow 10 % weighting to crypto assets besides already-approved BTC & ETH,” he noted, calling it “incongruent” to maintain different thresholds for digital assets.
Notably, regulatory engagement appears to have intensified. Grayscale filed an amended Form S-3 for GDLC on June 26, a move Geraci highlighted as evidence that “the SEC is clearly engaged.” The registration statement reiterates that NYSE Arca’s Rule 19b-4 proposal to list the shares cannot proceed without Commission sign-off, but it also supplies updated disclosure on custody, creation-unit size and index methodology—changes that typically occur only after iterative feedback from SEC staff.
If the conversion is approved this week, GDLC would become the first US spot ETF to give investors regulated exposure to XRP, Solana and Cardano, albeit in modest proportions. More importantly, it would hand the SEC real-time surveillance data on trading, flows and creation-redemption activity—data that could underwrite subsequent decisions on standalone XRP, SOL and ADA funds later in 2025. Market participants will know by the close of business Wednesday whether that experiment is about to begin.
At press time, XRP traded at $2.18.
