XRP ETF Race Begins as Major Firms Submit 19b-4 Filings

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The race to launch the first spot XRP ETF in the United States has officially entered a critical regulatory phase. Four major asset managers—WisdomTree, Bitwise, 21Shares, and Canary—are now one step closer to bringing XRP-based exchange-traded funds to market after submitting formal 19b-4 filings with the U.S. Securities and Exchange Commission (SEC) via the Cboe Exchange.

This coordinated move marks a pivotal moment in the ongoing evolution of cryptocurrency investment products. While spot Bitcoin and Ethereum ETFs gained approval in early 2024, XRP has remained in regulatory limbo due to its complex legal history. These new applications signal growing confidence among financial institutions that XRP can meet the SEC’s stringent listing requirements despite past uncertainties.

The Significance of the 19b-4 Filings

The 19b-4 form is a crucial regulatory requirement for any new ETF seeking approval to list and trade on a national securities exchange. It outlines the proposed rule change for listing the fund and provides detailed information about how the ETF will operate, including custody arrangements, pricing mechanisms, and anti-fraud safeguards.

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Each of the four filings—submitted by WisdomTree, Bitwise, 21Shares, and Canary—seeks approval to list shares of a spot XRP ETF on Cboe BZX. These applications follow earlier S-1 registration statements filed last year, with Bitwise taking an early lead in the process. Now, with both S-1 and 19b-4 submissions complete, these firms are positioned at the forefront of what could become a transformative development in digital asset investing.

Regulatory Challenges and Strategic Differentiation

What sets these XRP ETF proposals apart from previous attempts is their strategic use of recent legal developments—most notably, the July 2023 ruling in SEC v. Ripple Labs. In that case, Judge Analisa Torres determined that programmatic sales of XRP to retail investors did not constitute investment contracts under the Howey Test, effectively concluding that XRP is not a security in those contexts.

All four applicants cite this precedent directly in their filings:

“In light of these factors and consistent with applicable legal precedent, particularly as applied in SEC v. Ripple Labs, the Sponsor believes that it is applying the proper legal standards in making a good faith determination that it believes that XRP is not under these circumstances a security under federal law in light of the uncertainties inherent in applying the Howey and Reves tests.”

This argument forms the foundation of their case: if XRP is not a security when sold programmatically on exchanges, then a spot ETF holding such tokens should also fall outside securities regulations.

However, a key hurdle remains—the absence of a regulated futures market for XRP. Historically, the SEC has required a CME-traded futures contract as evidence of price transparency and resistance to market manipulation before approving spot commodity ETFs. Bitcoin and Ethereum both had established futures markets prior to their ETF approvals.

To address this gap, the applicants propose alternative surveillance mechanisms, including:

These tools aim to demonstrate that sufficient oversight exists to prevent fraud or manipulation, even without futures contracts.

Secondary Market Sourcing Strategy

Another distinguishing feature of these filings is their emphasis on sourcing XRP exclusively from secondary markets—such as licensed crypto exchanges—rather than directly from Ripple Labs.

This approach strategically sidesteps concerns raised by the SEC during its litigation with Ripple, where the regulator argued that certain institutional sales by Ripple constituted unregistered securities offerings. By purchasing XRP only after it has entered public circulation, the ETF sponsors aim to distance themselves from any potential regulatory taint associated with primary sales.

The structure mirrors that of successful spot Bitcoin ETFs, where custodians acquire BTC through open markets rather than directly from protocol developers or early miners.

Core Keywords Driving Market Interest

As investor interest in digital assets grows, several core keywords are shaping search behavior and media coverage around this evolving story:

These terms reflect both technical aspects of the approval process and broader public curiosity about when—and whether—XRP will join Bitcoin and Ethereum in having a U.S.-listed spot ETF.

Frequently Asked Questions (FAQ)

What is a 19b-4 filing?

A 19b-4 filing is a formal application submitted by a national securities exchange to the SEC requesting approval to list a new financial product, such as an ETF. It details how the product will operate and how market integrity will be maintained.

How long does the SEC take to review a 19b-4 filing?

The SEC typically has 45 days from publication in the Federal Register to make an initial decision. This period can be extended up to 90 days if the commission needs more time or if the exchange agrees to a delay.

Why is there no CME futures market for XRP?

Unlike Bitcoin and Ethereum, XRP has not yet been approved for futures trading on CME. This is largely due to ongoing regulatory uncertainty stemming from the SEC’s lawsuit against Ripple Labs. Without a futures benchmark, ETF sponsors must rely on other methods to prove price reliability.

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Can the SEC reject these XRP ETF applications?

Yes. The SEC has full authority to approve, disapprove, or initiate proceedings to potentially block the rule change. Given the unresolved appeal in SEC v. Ripple Labs, rejection remains a real possibility.

Are there other XRP ETF applications in progress?

Yes. Grayscale has also filed to convert its existing XRP Trust into an ETF on NYSE Arca. If approved, it would compete directly with these Cboe-listed proposals.

What happens if the SEC approves one or more of these ETFs?

Approval would allow investors to gain exposure to XRP through traditional brokerage accounts, increasing accessibility and potentially boosting liquidity and price stability. It could also set a precedent for other contested cryptocurrencies seeking similar products.

Broader Implications for Crypto Markets

The outcome of these filings could have far-reaching consequences beyond XRP alone. A favorable decision might encourage similar applications for other digital assets caught in regulatory gray areas—such as Cardano (ADA), Solana (SOL), or Polkadot (DOT)—especially if the SEC begins accepting non-futures-based validation models.

Moreover, institutional adoption could accelerate if investors gain confidence in regulated pathways to access high-potential assets previously deemed too risky.

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Even amid uncertainty, the mere act of filing signals shifting sentiment: major financial players are no longer waiting for perfect clarity—they’re shaping it through proactive engagement with regulators.

Final Outlook

The submission of four independent 19b-4 filings for spot XRP ETFs represents more than just corporate ambition—it reflects a maturing ecosystem where asset managers are leveraging legal precedents, technological tools, and market data to build compliant pathways into crypto finance.

While challenges remain—especially given the SEC’s ongoing appeal in the Ripple case—the momentum behind these applications suggests that the door may finally be opening for XRP’s entry into mainstream finance.

Investors should monitor two key developments:

  1. The SEC’s response timeline following Federal Register publication
  2. Any updates in the appellate process of SEC v. Ripple Labs

As this story unfolds, one thing is clear: the battle for crypto legitimacy is being fought not just in courts and codebases—but in regulatory filings and compliance frameworks.

This is a developing story.