Nasdaq has formally asked the U.S. Securities and Exchange Commission to approve the listing and trading of the Coinshares XRP ETF under Nasdaq Rule 5711(d), marking another attempt to expand regulated crypto investment products beyond bitcoin and ether. The proposed fund is structured as a Delaware statutory trust and is intended to give investors exposure to XRP without requiring them to directly buy, hold, or custody the token themselves.
According to the filing, the trust would hold only XRP and cash. Its performance would track the Compass Crypto Reference Index XRP – 4pm NY Time, while the fund’s net asset value would be calculated daily. The product is designed as a passive investment vehicle rather than an actively managed strategy, and the XRP held by the trust would be secured by a third-party custodian.
How the ETF would work
The filing outlines a creation and redemption process based on large blocks of shares known as baskets. These baskets would be available only to authorized participants, a structure commonly used in exchange-traded products. In practice, the trust would issue baskets on an ongoing basis in exchange for cash. That cash would then be used to acquire XRP, which would be placed with the custodian for safekeeping.
This framework is meant to provide a regulated access point for investors who want price exposure to XRP without dealing with private keys, self-custody, wallet management, or exchange-specific operational risks. Nasdaq’s argument is that an exchange-listed product can offer a more transparent and familiar wrapper for market participants, particularly those that prefer traditional securities infrastructure over direct digital asset ownership.
Nasdaq’s case on market integrity
A central part of Nasdaq’s submission is its claim that XRP is not particularly susceptible to manipulation, especially when compared with other reference assets that have already been approved for exchange-traded products. The exchange points to XRP’s deep liquidity, decentralized market structure, and broad global trading activity as key reasons why sustained price distortion would be difficult to engineer.
In the filing, Nasdaq argues that XRP trading is fragmented across multiple venues rather than concentrated in a narrow set of markets. In its view, this fragmentation reduces the likelihood that any single platform or participant could exert outsized control over price formation. The exchange also says that rising user engagement and trading volumes contribute to a market environment in which manipulation through continuous trading activity becomes harder to execute effectively.
Nasdaq further links this reasoning to the broader XRP network and its decentralized structure, presenting these traits as factors that support market resilience. The exchange’s position is that the scale and dispersion of XRP trading, combined with its ongoing adoption, limit the practical ability of bad actors to move the market in a sustained way.
Comparison with approved bitcoin and ether ETFs
To strengthen its argument, Nasdaq draws comparisons with previously approved bitcoin and ether ETFs. The filing suggests that the logic used to support those products can also apply to XRP, particularly in the context of liquidity, trading volume, and market surveillance considerations. While bitcoin and ether remain the most established assets in the U.S. spot ETF landscape, the XRP proposal signals an effort to push the regulatory conversation toward a broader set of digital assets.
Nasdaq’s position does not rest on direct equivalence between XRP and those assets. Instead, it argues that the core concerns typically raised by regulators—such as susceptibility to fraud or market manipulation—should be assessed in light of actual trading structure and market depth. On that basis, the exchange contends that XRP merits consideration within the same regulated product framework.
Why this filing matters
The proposal is significant because it reflects growing pressure to widen the menu of crypto-based exchange-traded products available to U.S. investors. If approved, the Coinshares XRP ETF would offer a new route for institutions and retail investors to access XRP through standard brokerage accounts, rather than through direct participation in crypto markets.
Such a product could also carry symbolic importance. Approval would indicate that U.S. regulators are willing to evaluate crypto ETFs beyond the two largest digital assets, potentially setting a benchmark for how other token-based products are assessed. Even if the SEC ultimately takes a cautious stance, the filing itself shows that exchanges and issuers are actively testing where the regulatory boundaries now stand.
SEC review now underway
The SEC is currently reviewing Nasdaq’s proposal and has invited public comment before reaching a final decision. As with other exchange rule-change filings tied to crypto products, the process will likely focus on whether the proposed listing meets standards related to investor protection, market integrity, and fair surveillance arrangements.
For now, the outcome remains uncertain. What is clear is that Nasdaq has framed the case around a straightforward thesis: XRP’s liquidity, decentralized trading footprint, and global activity make it harder to manipulate than critics may assume. Whether that argument proves persuasive with the SEC will determine if the Coinshares XRP ETF becomes a new milestone in the evolution of regulated crypto investing in the United States.

