The approval process by the SEC has been significantly simplified, and crypto ETFs may see a surge. What does this mean for investors?

Original Author | SoSoValue Research
Original Editor | Wu Says Blockchain

On September 17, the U.S. SEC officially approved the "General Listing Standards for Commodity Trust Shares" (Release No. 34--103995). This is not a simple technical document, but a true "institutional gateway" --- --- meaning that the listing of cryptocurrency spot ETFs in the future will shift from case-by-case approval to a standardized, expedited general standard process.

Against the backdrop of the Federal Reserve just starting a new round of interest rate cuts and rising expectations of U.S. dollar depreciation, this institutional breakthrough brings a dual resonance of "liquidity + institutionalization" to crypto assets, making it one of the most iconic regulatory events in the crypto market this year.

In this article, we will answer the following questions:

• What exactly has changed with the new regulations, and what impacts will it bring?
• Which cryptocurrencies are likely to benefit first, and which coins' spot ETFs are expected to be approved first?
• What should investors pay attention to? In the context of the new regulations and the reshaping of capital migration logic, how can ordinary investors seize opportunities and manage risks?

1. What has changed with the general standards? From "whether to allow" to "how to regulate"

Before the release of this new regulation, cryptocurrency spot ETFs had to go through a case-by-case approval process, crossing two approval thresholds:

1. 19b-4 Rule Change Approval --- --- Exchanges apply to the SEC to amend exchange rules, which is a substantive approval and carries the possibility of being rejected by the SEC.

2. S-1 Prospectus Approval --- --- ETF issuers submit for SEC approval, disclosing details such as fund structure, managers, and fees, which is more of a formal review.

This dual approval model is not only lengthy but is often slowed down by political maneuvering and compliance disagreements. For example, the Bitcoin spot ETF saw a surge in applications in 2021, but in 2021-2022, it was rejected by the SEC at the 19b-4 stage. From May to July 2023, a new batch of applications was submitted, and it wasn't until January 10, 2024, that the 19b-4 and S-1 documents were approved on the same day, experiencing nearly eight months of back-and-forth.

The "General Listing Standards" approved by the SEC on September 17, 2025, brings fundamental changes. This standard clarifies that eligible commodity ETFs no longer need to submit 19b-4 applications on a case-by-case basis, but only need to go through the S-1 approval process, significantly reducing approval time and costs.

ETFs that meet the standards must satisfy one of the following three paths:

1. The underlying commodity has been traded on ISG (Intermarket Surveillance Group) member markets, such as the NYSE, Nasdaq, CME, London Stock Exchange, etc.

2. The futures contracts of the underlying commodity have been continuously traded on a DCM (Designated Contract Market) for at least six months, and a Comprehensive Surveillance Sharing Agreement (CSSA) has been established between exchanges. DCMs are compliant exchanges authorized by the CFTC (Commodity Futures Trading Commission), such as CME, CBOT, Coinbase Derivatives Exchange, etc.

3. An ETF has already been listed on a national securities exchange in the U.S., and at least 40% of its assets are allocated to the underlying commodity.

Since most crypto assets are considered "commodities," this rule is almost tailor-made for cryptocurrency spot ETFs. Among these, the second path is the most feasible: as long as a certain crypto asset has futures contracts running for six months on exchanges like CME or Coinbase Derivatives, it can skip the 19b-4 approval stage, and its spot ETF is expected to be launched quickly. Figure 1: Approval process for new and old cryptocurrency spot ETFs (Data Source: SoSoValue)

Compared to the old model, the changes brought by the new regulations mainly reflect in two aspects:

1) Simplified approval path: 19b-4 is no longer a "roadblock."

Under the old model, cryptocurrency spot ETFs needed to complete both the 19b-4 rule change and S-1 prospectus approvals simultaneously, with neither being dispensable. The past Bitcoin and Ethereum ETFs were like this: the review time for 19b-4 lasted up to 240 days, becoming a key factor slowing down the process. In the new regulations, as long as the product meets the unified standards, the exchange can directly proceed with the S-1 approval process, eliminating the repeated negotiations of 19b-4, significantly shortening the listing cycle.

2) Shift in the focus of review authority: CFTC and DCM play a more critical role.

The qualification review of futures contracts is gradually shifting from the SEC to DCMs (Designated Contract Markets) and the CFTC (Commodity Futures Trading Commission). According to the current system, DCMs have two main ways to launch new contracts:

• Self-Certification: DCMs only need to submit a self-declaration to the CFTC one business day before the contract goes live; if there are no objections, the contract automatically takes effect. This usually requires the spot market to have price transparency, sufficient liquidity, and manageable market manipulation risks.
• Voluntary Approval: If there are disputes regarding the contract, DCMs can proactively apply for CFTC approval to obtain stronger legal protection.

This means that as long as the spot market for a certain type of crypto asset is healthy enough, DCMs have considerable autonomy to promote its futures listing. Meanwhile, the SEC's review of S-1 mainly focuses on whether the information disclosure is sufficient and whether the product structure is compliant, which is more of a "formal review."

Overall, the SEC is transitioning from a case-by-case approver to a rule maker. The regulatory attitude is also shifting from "whether to allow" to "how to regulate." Under this framework, the launch of cryptocurrency spot ETFs will be more efficient and standardized.

2. Which cryptocurrencies are most likely to benefit? The 10 mainstream coins with existing futures contracts & ETF applications will be the first to see ETF launches.

Among the existing DCMs (Designated Contract Markets), Coinbase's Coinbase Derivatives Exchange has the most comprehensive line of crypto futures products, currently covering 14 cryptocurrencies. (See Figure 2). Figure 2: List of futures already listed on Coinbase (Data Source: SoSoValue)

According to SoSoValue data, there are currently 35 cryptocurrency spot ETFs queued for approval, covering 13 coins. Except for SUI, TRX, and JitoSOL, the remaining 10 coins have already had futures listed on Coinbase Derivatives for over six months, thus fully meeting the new general requirements. Figure 3: The 10 mainstream coins with existing futures contracts & ETF applications will be the first to see ETF launches (Data Source: SoSoValue)

This means:

• About 30 spot ETFs covering 10 coins including LTC, SOL, XRP, DOGE, ADA, DOT, HBAR, AVAX, LINK, BCH are expected to be quickly approved in the coming weeks or months;
• The market is brewing the next wave of ETF "explosion." For example, while coins like XLM and SHIB already have futures, no one has submitted spot ETF applications yet, making them likely targets for the next batch of managers.

3. When the interest rate cut cycle meets the ETF explosion, what should investors pay attention to? ETF issuance progress, macro interest rate trends, cross-asset allocation, and capital flows

In the short term, the implementation of the general standards will significantly accelerate the pace of cryptocurrency ETF launches, lower issuance thresholds, and attract more institutional funds and compliant products into the market.

At the same time, the Federal Reserve lowered interest rates by 25 basis points as expected on Thursday, signaling two more cuts within the year, marking the beginning of a rate cut cycle, and expectations of U.S. dollar depreciation are beginning to take shape, with global capital searching for new asset anchors.

The collision of macro liquidity and institutional innovation: on one side is the massive liquidity released by the dollar system, and on the other side is the potential product explosion of cryptocurrency ETFs. The intertwining of the two may reshape capital allocation logic, accelerate the deep integration of traditional capital markets and crypto assets, and may even become the starting point for a reconfiguration of the global asset landscape in the next decade.

In this context, investors need to focus on four aspects:

1. ETF issuance pace: For cryptocurrency spot ETFs that meet the general rules, the S-1 will often update the prospectus multiple times before final approval, supplementing details such as fees and initial issuance scale. These updates often indicate that the product is entering the "countdown" to listing.

2. Macro environment: The Federal Reserve's interest rate path, dot plot expectations, and U.S. dollar index trends will determine the direction of risk appetite switches, which are core clues for asset pricing. Figure 4: Federal Reserve interest rate path expectations (Data Source: SoSoValue)

3. Cross-asset allocation: During periods of dollar weakness, gold, commodities, and crypto assets often complement each other. By diversifying exposure, investors can reduce risks while capturing multiple yield curves.

4. Capital flows: Compared to price fluctuations, the daily net inflows of ETFs can better reflect market sentiment and trends, often possessing stronger foresight, helping investors seize opportunities before market reversals. Figure 5: Daily net inflow of Bitcoin spot ETF (Data Source: SoSoValue) Figure 6: Daily net inflow of Ethereum spot ETF (Data Source: SoSoValue)

In summary, the new regulations combined with the interest rate cut cycle are opening a "dual gateway" of institutions and liquidity for cryptocurrency ETFs. For investors, this represents a new window of opportunity and a deep reshaping of asset allocation logic.

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