Nasdaq has submitted a 19b-4 filing to the US Securities and Exchange Commission (SEC) seeking approval to list the 21Shares SUI ETF.

The filing, which is now published in the SEC’s public register, initiates the formal beginning of the regulatory review process and follows 21Shares’ S-1 registration statement, which was filed in April.

Bringing SUI ETF to US Market

The proposed fund signals growing institutional interest in the Sui ecosystem, a Layer 1 blockchain known for its high throughput and developer-friendly architecture. 21Shares already offers a Sui exchange-traded product (ETP) in Europe, following listings on Euronext Paris and Amsterdam, and the products have seen a surge in inflows in recent months.

In fact, Sui Foundation revealed that more than $300 million is allocated to SUI-based investment products globally. As such, a successful US launch is expected to provide broader access to the network and its token. Interest in Sui has extended beyond 21Shares, with firms including Canary Capital, Franklin Templeton, VanEck, Grayscale, and Ant Financial rolling out various initiatives tied to the network since late 2024.

In an official statement, Kevin Boon, President of Mysten Labs, said,

“The Sui ecosystem has become a primary destination for serious builders and institutions, and 21Shares has built its legacy on identifying those trends early. Looking back at our mainnet only two years ago, the milestone of a NASDAQ filing is a powerful moment. We are proud to help 21Shares build towards a world where every investor can access SUI.”

Sui Q1 Performance

Sui’s DeFi ecosystem gained significant momentum in Q1, as the average daily DEX volume reached a record $304.3 million, up 14.6% quarter-over-quarter. Cetus and Bluefin dominated trading, while Kriya, DeepBook, and Turbos contributed to liquidity diversification.

Despite this growth, the SUI token struggled during the period, with its circulating market cap plunging 40.3% to $7.2 billion, double the broader market’s 18.2% decline.

The altcoin saw a brief respite in mid-May and was trading near the $3.96 mark but declined shortly thereafter as it experienced increased volatility and bottomed out below $3.00 in early June, along with the broader market drawdown. However, it has since rebounded, climbing back to approximately $3.50 by June 11.

VanEck, 21Shares, and Canary Capital requested on June 5 that the US Securities and Exchange Commission (SEC) reinstate the queue-based review system that awards exchange-traded product approvals in the order issuers filed. 

In a joint letter to Chair Paul Atkins, the firms said concurrent approvals strip early filers of the advantage that traditionally offsets higher legal and compliance costs.

In the letter, VanEck chief executive Jan van Eck, Canary’s Steve McClurg, and 21Shares president Duncan Moir asked the SEC to apply the filing-date principle to pending products, including any future Solana exchange-traded funds (ETFs) submissions.

The letter also calls on the regulator to “nurture a competitive financial marketplace” by restoring predictable timelines.

Stalled first-mover advantage

The letter argued that departures from the queue began in October 2021, when the ProShares Bitcoin Futures Fund received a three-day head start and secured more than 90% of the market share. 

Early filers for spot Bitcoin and Ethereum ETFs later saw their applications cleared on Jan. 10, 2024, the same day larger asset managers that filed months or years later received green lights. 

The firms contend that such timing favors issuers with deeper distribution networks, encourages copycat filings, and concentrates assets under bigger brands.

The authors said the pattern harms market integrity by weakening incentives for original research and discouraging smaller sponsors from taking early risks. 

They also noted that honoring filing dates would not add material strain on SEC staff because registration statements already arrive in sequence and can retain their original time gaps through the review cycle.

Calls echo prior public remarks

VanEck digital assets research chief Matt Sigel has repeated the queue argument since 2024. On May 23, 2024, Sigel warned that deviations undercut the Administrative Procedure Act’s transparency standard and force early filers to shoulder prolonged update expenses.

He added that refusing to follow this standard “creates an uneven playing field for issuers who filed earlier and had to wait longer.”

On January 22, Sigel urged the regulator’s new leadership to “respect the line” after the agency formed its Crypto Task Force. 

Canary Capital chief executive Steve McClurg previewed the coordinated push during a late-May panel at the Litecoin Summit in Las Vegas, telling attendees that several issuers planned a formal appeal for a return to the queue. 

Bloomberg ETF analyst James Seyffart also commented on the letter, stating that the first-to-file approach was standard practice until the 2024 launches of the spot Bitcoin and Ethereum ETFs.

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The US Securities and Exchange Commission (SEC) extended its review of two high-profile proposals for spot Solana (SOL) exchange-traded funds, signaling further delays in the approval process for crypto-linked investment products.

The agency said it would begin a new round of proceedings to assess whether the ETF proposals from asset managers Bitwise and 21Shares comply with key provisions of the Securities Exchange Act.

Specifically, the SEC cited concerns related to market manipulation and investor protection, factors it is obligated to weigh before granting any ETF listing.

Prolonged wait

Bitwise’s application, filed in January through Cboe’s BZX Exchange, and 21Shares’ separate proposal have now each been delayed at least once.

While both firms have experience offering crypto investment products, 21Shares already manages approved Bitcoin (BTC) and Ethereum (ETH) ETFs. The SEC has yet to authorize any fund tied to Solana, a blockchain often touted as a faster, lower-cost alternative to Ethereum.

The regulator said it is seeking additional public input and analytical time to determine whether the proposed rule changes would meet its standards for preventing fraud and ensuring investor confidence.

The regulator’s cautious tone suggests that Solana, despite its rising prominence, may face a longer path to ETF approval than its predecessors.

Regulatory inertia

The delay comes amid a broader regulatory bottleneck affecting several digital asset ETFs. The regulator has postponed decisions on several crypto ETFs in recent weeks and months. Nonetheless, optimism remains strong in the market.

Bloomberg analysts James Seyffart and Eric Balchunas have previously stated that they expect high chances of approval for most ETF applications, with the final green light anticipated sometime in the latter half of the year.

They estimated a 90% likelihood of eventual approval for both Solana and Litecoin (LTC) ETFs, attributing their optimism to favorable commodity classifications and rising institutional interest.

However, with final decisions potentially months away and broader policy uncertainty lingering, investors may be forced to wait until late 2025 for clarity on whether Solana ETFs will make it to US markets.

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Solana (SOL) has emerged as the fastest-growing Layer 1 blockchain of 2025, surpassing Ethereum (ETH) in developer growth and gaining ground across DeFi, payments, and AI, according to 21Shares’ latest State of Crypto report.

In the first two months of the year alone, Solana processed $364 billion in volume, more than Ethereum and Coinbase, and now supports over 100 million monthly active users.

With average fees under $0.01 and sub-second transaction finality, Solana’s high-speed, low-cost architecture is driving adoption from both crypto-native users and major institutions.

Visa, Shopify, and Stripe are now settling stablecoin payments on Solana, while PayPal and First Digital hold over $100 million in Solana-native assets.

Stablecoin supply on the network has jumped 600% year-over-year, exceeding $12 billion as of the end of the first quarter.

DeFi, memecoins, and AI push

Solana’s DeFi ecosystem has grown to $8 billion in total value locked, up 100% from 2024, and now accounts for 16% of Ethereum’s market share, narrowing a once 20:1 gap to 5:1.

It hosts three of the top 10 DEXs by volume and ranks third globally in stablecoin market cap.

Memecoins remain a key driver of activity, contributing more than half of on-chain volume. The Official TRUMP token launched earlier this year generated $30 billion in trades over 48 hours, temporarily pushing Solana’s throughput to levels rivaling Nasdaq.

Beyond speculation, the network is rapidly expanding into infrastructure and AI. Solana leads all chains in DePIN market cap at $4.2 billion, supporting projects like Helium, Hivemapper, and Render Network.

Solana also dominates the crypto-AI segment, with 66% of AI agent activity and growing adoption of tools like ElizaOS and Arc.

Valuation models suggest significant upside

The report highlights rising concerns around validator centralization, speculative activity, and inflationary pressure following the end of transaction fee burns.

However, the report argued that Solana remains fundamentally undervalued. A discounted cash flow model projects SOL’s fair value between $520 and $1,800, depending on growth rates, far above its current price of around $150.

If Solana captures just half of Ethereum’s market cap, it could see continued growth in payments, AI, and institutional adoption.

The report concluded that Solana is positioned as the primary Layer 1 competitor and the backbone of next-generation blockchain infrastructure.

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A modest 1% allocation to Dogecoin (DOGE) could significantly improve portfolio returns without meaningfully increasing risk, according to a new analysis by crypto investment firm 21Shares.

In its April report, the firm evaluated how Dogecoin performs when added to a Bitcoin-enhanced growth strategy.

Stress-tested portfolios

The firm’s portfolio stress-testing showed that the baseline portfolio, a conventional 60/40 mix of stocks and bonds, returned 7.25% annually.

Meanwhile, including a 3% Bitcoin and 1% Dogecoin allocation increased annualized returns to as high as 8.95%. Sharpe ratios improved in nearly all simulations, suggesting better risk-adjusted performance.

Although the addition introduced some volatility, the increase in maximum drawdown was only marginal, and even without rebalancing, the losses remained contained.

The report emphasized that rebalancing is essential, especially monthly or weekly, to maintain return potential and prevent risk from building up quietly during turbulent markets. The firm attributed Dogecoin’s effectiveness to its low correlation with both traditional assets and the wider crypto market, along with a strong historical return profile.

According to 21Shares, this makes Dogecoin a viable diversifier rather than just a speculative meme.

Dogecoin’s potential path

The report outlined three price projections for Dogecoin in the current market cycle: a bear case, a neutral case, and a bull case.

In the bear case, 21Shares argued that Dogecoin’s recent rally may have already priced in much of its cycle potential.

If the token compounds at 10% annually from its 2021 high of 0.73, it would reach approximately 0.38 by late 2025. This would still be more than double its current value but would mark the first time Dogecoin fails to set a new all-time high within a full market cycle.

In the neutral case, the firm assumed the total crypto market cap would peak at $5 trillion, with Dogecoin maintaining a 3% share. This scenario would result in a DOGE market capitalization of about $150 billion, implying a price near $1 per coin.

This assumes the token continues to lead the memecoin category while adapting to increased competition and changing retail trends.

The bull case relies on historical cycle growth. Between its 2018 low of $0.007 and the 2022 cycle bottom of $0.0585, Dogecoin posted a compounded annual growth rate of 189%.

If DOGE mirrors that trajectory this cycle, it would rise to approximately $1.42. To achieve this, 21Shares said the token would need support from renewed retail enthusiasm, increased adoption, and integration with platforms such as X.

The firm concluded that with proper structure and rebalancing, a small allocation to Dogecoin is not reckless but potentially rewarding.

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