Altcoins
|3 min ReadDogecoin ETF launches in US under 1940 Act rules
Maya Chen
Senior Analyst
Published
Jan 16, 2026
How this fund is built, and why it matters
Bloomberg’s Eric Balchunas flagged the Rex-Osprey Doge ETF, ticker DOJE, as the launch vehicle. He wrote, “Pretty sure this is first-ever U.S. ETF to hold something that has no utility on purpose.” The structure is the twist. The fund comes under the Investment Company Act of 1940. Most crypto products have gone the 1933 Securities Act route as commodity-style grantor trusts.
Ganesh Mahidhar of Further Ventures told Decrypt that 1940 Act ETFs carry diversification mandates and broader governance requirements. In his words, regulating it under the 1940 Act “provides more investor protection and imposes a registered investment structure on the SPV offering it.” He added that this framework makes the product more like stock and bond ETFs, while the BTC ETF is closer to a commodity ETF.
The meme coin label raises a bigger question. If DOJE clears, do others follow. The pipeline is heavy. Bloomberg’s James Seyffart counts 92 crypto ETF filings on the SEC’s desk, led by XRP and Solana. Deadlines stretch into October.
What sets DOGE apart, and who bites first
Mahidhar noted that Dogecoin uses proof of work like Bitcoin. That gives it a production “floor” tied to power consumption. He contrasted it with Shiba Inu and Pepe. Those run on proof of stake and “don’t have the same baseline,” making them more vulnerable “due to lack of utility,” he said. He still sees app-chain and layer 2 projects pushing gaming or gambling use cases over time.
Do institutions jump in now. He thinks not yet. Large portfolios are “unlikely to touch the ETFs at this stage.” If market cap grows, attention follows. In this trade, price action and volatility matter more than narratives. Utility can come later. Traders know the drill. Liquidity first. Story second.
Meanwhile the docket stays crowded. The SEC delayed a decision on Nasdaq’s bid to list Grayscale’s Hedera Trust, moving the deadline to November 12. On the same day, Grayscale updated registrations for its Bitcoin Cash and Litecoin trusts on Form S-3. REX Shares also filed in January for multiple crypto ETFs, including Trump, BONK, and more Dogecoin products, shortly after Gary Gensler left the SEC.
The setup right now
The takeaway is simple. A 1940 Act wrapper puts DOGE inside the mainstream ETF playbook. That invites new buyers who cannot hold coins directly. It also tests how far meme assets can travel on regulated rails. If the product trades well, copycats line up. If flows stick, the SEC’s logjam gets harder to hold.
For now, CoinGecko shows DOGE near $0.24, up 1.4 percent on the day and 11.7 percent on the week. The tape will tell you the rest. Watch volume. Watch spreads. If money shows up here, the market will not ignore it.
Disclaimer: This document is intended for informational and entertainment purposes only. The views expressed in this document are not, and should not be taken as, investment advice or recommendations. Recipients should do their own due diligence, taking into account their specific financial circumstances, investment objectives and risk tolerance, which are not considered here, before investing. This document is not an offer, or the solicitation of an offer, to buy or sell any of the assets mentioned.