REX-Osprey’s Unprecedented Filing of 21 Cryptocurrency ETFs: A Comprehensive Analysis

In a bold and unprecedented move, REX-Osprey—formed through a partnership between REX Shares and Osprey Funds—recently applied to the U.S. Securities and Exchange Commission (SEC) for 21 cryptocurrency-based exchange-traded funds (ETFs). This landmark filing, which took place on October 3, 2025, has caught the attention of both financial markets and the crypto industry, signaling a potential seismic shift in how digital asset investments are structured and offered to the public.

Extensive Cryptocurrency Coverage with Staking Capabilities

The filing showcases a diverse and carefully chosen lineup of major cryptocurrencies, including key tokens like Cardano (ADA), Avalanche (AVAX), Polkadot (DOT), Near Protocol (NEAR), Sei (SEI), Sui (SUI), Bittensor (TAO), and Hype (HYPE). What sets these proposed ETFs apart is the inclusion of staking functionality in several of the products, offering investors the potential to earn staking rewards alongside traditional capital appreciation. This dual approach caters to both speculative traders seeking growth and long-term investors focused on yield generation.

By integrating staking rewards within the ETF structure, REX-Osprey is taking a groundbreaking step that highlights a growing demand for hybrid investing strategies. This innovation aligns with broader trends in the crypto ecosystem, where staking plays a crucial role in incentivizing network security and decentralization while providing steady income opportunities for token holders.

A Cayman Islands Subsidiary Structure for Regulatory Compliance

To remain compliant with U.S. tax laws and regulatory standards, REX-Osprey plans to adopt a Cayman Islands subsidiary structure. This architecture mirrors the operational setup of other U.S.-listed investment funds and allows the ETFs to qualify as regulated investment companies. Under this structure, the funds can allocate up to 40% of their assets to pre-existing crypto-related products listed in international markets, such as those offered by industry leaders like 21Shares, CoinShares, and Valour.

This framework enhances the ETF offering by tapping into the liquidity and established credibility of European and Canadian-listed crypto products, while adhering to the stringent requirements of the U.S. Investment Company Act. This strategic decision underscores how issuers are navigating the complex intersection of international crypto markets and domestic compliance obligations.

Driving Forces: The Solana Staking ETF and Simplified SEC Processes

The timing of REX-Osprey’s massive filing appears to be influenced by two significant developments in the ETF landscape. First, the notable success of the Solana (SOL) Staking ETF has underscored the market appetite for staking-focused products. Solana's ETF not only captured investor interest but also demonstrated the viability of integrating staking rewards into ETF structures—a blueprint REX-Osprey seems eager to expand upon with its multi-token ETF lineup.

Additionally, the SEC’s recent adoption of simplified listing standards for commodity-based trust shares has created an expedited pathway for new ETF products. These updated rules, which streamline the review process and reduce regulatory barriers, have eliminated the need for the notoriously lengthy 19b-4 rule review. As a result, ETF issuers can now aim for faster approval times, further motivating innovative filings like that of REX-Osprey.

Potential Delays Due to U.S. Government Shutdown

Despite these regulatory efficiencies, external factors—namely, the current U.S. federal government shutdown—could impede the approval timeline for REX-Osprey’s groundbreaking ETFs. With key government agencies, including the SEC, operating under restricted capacity, the final decision on these filings could face significant delays. Regulatory bottlenecks stemming from the shutdown may push back the launch dates of these funds, leaving investors and issuers in a state of uncertainty.

Emerging Competition in the ETF Ecosystem

REX-Osprey’s aggressive strategy comes at a time when competition in the cryptocurrency ETF space is heating up. On the same day as their filing, Defiance ETFs joined the race by submitting an application for a leveraged ETF product tied to both digital assets and major corporations like Tesla and Amazon. This development highlights the intensifying battle among issuers to capture market share in the burgeoning crypto-backed ETF sector.

Industry experts, including Bloomberg Intelligence analyst James Seyffart, have remarked on this rush of ETF activity, with Seyffart stating, “ETF application activity is heating up.” The filing frenzy reflects the escalating interest in providing retail and institutional investors with easier access to cryptocurrency exposure under regulated investment vehicles.

Conclusion: A Turning Point for Digital Asset Regulation

REX-Osprey’s ambitious application for 21 cryptocurrency ETFs represents a pivotal moment not only for the burgeoning crypto ETF market but also for the broader push toward mainstream adoption and regulation of digital assets. With innovative features like staking rewards, adherence to a rigorous compliance framework, and the backing of international crypto products, these funds could redefine investor access to digital currencies.

As the SEC evaluates this historic batch of applications, the financial industry will be closely watching how these developments shape the future of crypto investing. Whether or not external factors like the government shutdown cause delays, REX-Osprey’s filing has already left a significant mark, signaling a new era of creativity and competition in the ETF realm.