<100 subscribers
On 17 September 2025 the U.S. Securities and Exchange Commission quietly published Release No. 34-103995, a 200-page technical document with a one-line market takeaway: crypto spot-ETFs no longer need case-by-case approval.
Instead, any fund that meets three pre-defined “commodity-trust” criteria can list after a fast-track S-1 review, scrapping the 19b-4 rule-change procedure that has killed dozens of applications since 2018.
The reform lands just as the Federal Reserve fires the starting pistol on a new easing cycle—25 bp cut last Thursday, dot-plot pointing to two more before year-end—giving digital assets a rare double boost: looser regulation plus cheaper dollars.
Below we answer the questions every investor is now asking:
What exactly changed?
Which coins are first in line?
How do you trade the rollout without getting burned?
1. From “Permission Denied” to “Follow the Checklist”
Old regime
Step 1 – Exchange files 19b-4 (rule change) → SEC can kill the product on policy grounds.
Step 2 – Issuer files S-1 (prospectus) → SEC focuses on disclosure.
Both had to be signed off on the same day; 19b-4 alone could take 240 days and was vetoed in 2021-22 for every spot-bitcoin ETF.
New regime
If the underlying asset satisfies any one of three safe-harbour tests, only the S-1 remains.
Test A – Spot market exists on an ISG exchange (NYSE, NASDAQ, LSE, CME …).
Test B – Futures have traded on a CFTC-designated contract market (DCM) for ≥ six months and the exchange has a comprehensive surveillance-sharing agreement (CSSA) with that DCM.
Test C – A U.S.-listed ETF already holds ≥ 40 % of its assets in the commodity.
Because almost every large-cap crypto is treated as a commodity, Test B is the practical pathway: once a CME or Coinbase Derivatives futures contract has run for six months, a spot ETF can skip the 19b-4 gauntlet.
The SEC keeps a light hand on the S-1, while the CFTC and the DCMs become the real gatekeepers—largely through self-certification that can be completed in 24 hours.
Bottom line: the agency has moved from “mother, may I?” to “file the paperwork and list”.
2. Ten Coins, ~30 ETFs—Ready to Launch
Coinbase Derivatives already lists futures on 14 cryptocurrencies; 10 of them have had continuous contracts for more than six months and already have at least one live S-1 filing:
Litecoin (LTC)
Solana (SOL)
XRP
Dogecoin (DOGE)
Cardano (ADA)
Polkadot (DOT)
Hedera (HBAR)
Avalanche (AVAX)
Chainlink (LINK)
Bitcoin Cash (BCH)
Roughly 30 prospectuses covering these coins are now in the queue; updated fee tables and seed-capital paragraphs are being filed almost daily—standard sign that final effectiveness is days or weeks away.
Coins such as Stellar (XLM) and Shiba Inu (SHIB) also meet the six-month futures test but have no S-1 on file yet; expect asset-management boutiques to pounce quickly now that the roadmap is public.
3. What to Watch: Calendar, Coupons and Flows
ETF countdown
Each amended S-1 is a ticking clock. When the fee, ticker and initial seed amount stop changing, the effectiveness notice usually follows within 5–10 trading days. Watch the SEC’s EDGAR “ EFFECT ” tag, not Twitter rumors.
Rates and the dollar
Fed-funds futures price a further 50 bp of cuts by March 2026; DXY below 100 is the line in the sand. A soft dollar historically pushes non-yielding stores of value—gold, commodities, crypto—higher in lock-step.
Cross-asset playbook
In weak-dollar regimes a 60/30/10 barbell—broad commodities / gold / crypto—has beaten equities on a risk-adjusted basis in four of the last five cycles. Rebalance monthly; use ETF inflows, not price, as the leading indicator.
Flow > price
Spot-bitcoin ETFs traded $6.8 bn net inflow in the first four days after the Fed cut, while BTC spot price barely budged—classic signal that the next leg had already started. Ethereum ETFs saw the same pattern in August. Daily creation/redemption data are published each evening at 20:00 ET; treat them as the new “tape”.
Takeaway
The SEC’s generic-listing rule has replaced regulatory roulette with a checklist, while the Fed is spraying dollar liquidity across global markets.
For the first time in crypto’s short history, both gates—regulatory and monetary—are opening at once.
Traders no longer bet on “if” an ETF launches; they position for how fast the inflows arrive and which coin is next in line.
On 17 September 2025 the U.S. Securities and Exchange Commission quietly published Release No. 34-103995, a 200-page technical document with a one-line market takeaway: crypto spot-ETFs no longer need case-by-case approval.
Instead, any fund that meets three pre-defined “commodity-trust” criteria can list after a fast-track S-1 review, scrapping the 19b-4 rule-change procedure that has killed dozens of applications since 2018.
The reform lands just as the Federal Reserve fires the starting pistol on a new easing cycle—25 bp cut last Thursday, dot-plot pointing to two more before year-end—giving digital assets a rare double boost: looser regulation plus cheaper dollars.
Below we answer the questions every investor is now asking:
What exactly changed?
Which coins are first in line?
How do you trade the rollout without getting burned?
1. From “Permission Denied” to “Follow the Checklist”
Old regime
Step 1 – Exchange files 19b-4 (rule change) → SEC can kill the product on policy grounds.
Step 2 – Issuer files S-1 (prospectus) → SEC focuses on disclosure.
Both had to be signed off on the same day; 19b-4 alone could take 240 days and was vetoed in 2021-22 for every spot-bitcoin ETF.
New regime
If the underlying asset satisfies any one of three safe-harbour tests, only the S-1 remains.
Test A – Spot market exists on an ISG exchange (NYSE, NASDAQ, LSE, CME …).
Test B – Futures have traded on a CFTC-designated contract market (DCM) for ≥ six months and the exchange has a comprehensive surveillance-sharing agreement (CSSA) with that DCM.
Test C – A U.S.-listed ETF already holds ≥ 40 % of its assets in the commodity.
Because almost every large-cap crypto is treated as a commodity, Test B is the practical pathway: once a CME or Coinbase Derivatives futures contract has run for six months, a spot ETF can skip the 19b-4 gauntlet.
The SEC keeps a light hand on the S-1, while the CFTC and the DCMs become the real gatekeepers—largely through self-certification that can be completed in 24 hours.
Bottom line: the agency has moved from “mother, may I?” to “file the paperwork and list”.
2. Ten Coins, ~30 ETFs—Ready to Launch
Coinbase Derivatives already lists futures on 14 cryptocurrencies; 10 of them have had continuous contracts for more than six months and already have at least one live S-1 filing:
Litecoin (LTC)
Solana (SOL)
XRP
Dogecoin (DOGE)
Cardano (ADA)
Polkadot (DOT)
Hedera (HBAR)
Avalanche (AVAX)
Chainlink (LINK)
Bitcoin Cash (BCH)
Roughly 30 prospectuses covering these coins are now in the queue; updated fee tables and seed-capital paragraphs are being filed almost daily—standard sign that final effectiveness is days or weeks away.
Coins such as Stellar (XLM) and Shiba Inu (SHIB) also meet the six-month futures test but have no S-1 on file yet; expect asset-management boutiques to pounce quickly now that the roadmap is public.
3. What to Watch: Calendar, Coupons and Flows
ETF countdown
Each amended S-1 is a ticking clock. When the fee, ticker and initial seed amount stop changing, the effectiveness notice usually follows within 5–10 trading days. Watch the SEC’s EDGAR “ EFFECT ” tag, not Twitter rumors.
Rates and the dollar
Fed-funds futures price a further 50 bp of cuts by March 2026; DXY below 100 is the line in the sand. A soft dollar historically pushes non-yielding stores of value—gold, commodities, crypto—higher in lock-step.
Cross-asset playbook
In weak-dollar regimes a 60/30/10 barbell—broad commodities / gold / crypto—has beaten equities on a risk-adjusted basis in four of the last five cycles. Rebalance monthly; use ETF inflows, not price, as the leading indicator.
Flow > price
Spot-bitcoin ETFs traded $6.8 bn net inflow in the first four days after the Fed cut, while BTC spot price barely budged—classic signal that the next leg had already started. Ethereum ETFs saw the same pattern in August. Daily creation/redemption data are published each evening at 20:00 ET; treat them as the new “tape”.
Takeaway
The SEC’s generic-listing rule has replaced regulatory roulette with a checklist, while the Fed is spraying dollar liquidity across global markets.
For the first time in crypto’s short history, both gates—regulatory and monetary—are opening at once.
Traders no longer bet on “if” an ETF launches; they position for how fast the inflows arrive and which coin is next in line.


Share Dialog
Share Dialog
No comments yet