Fundamentally, a U.S. Securities and Exchange Commission (SEC) Form 19b-4 serves as a procedural filing intended to propose modifications to the rules of the SEC. Although it represents an essential step in the quest for regulatory approval for changes such as listing new financial products, the filing itself does not guarantee approval or indicate that any action is imminent.

Cboe’s 19b-4 filings advocate rule changes intended to permit these XRP ETFs to be listed and traded, thereby triggering a 240-day review period during which the SEC must approve, deny, or extend its decision-making process. In contrast to bitcoin (BTC) and ethereum (ETH), which benefit from established futures markets on the CME that helped streamline ETF approvals, XRP does not have a similar market.

XRP/USD 1D chart via Bitstamp on Feb. 6, 2025.

To remedy this gap, the applicants propose alternative safeguards such as onchain analytics and market structure analysis to mitigate risks of fraud and manipulation. In addition to Cboe, last week, NYSE Arca posted a 19b-4 filing for Grayscale’s XRP trust, which like Grayscale’s bitcoin and ethereum trust predecessors would change from over-the-counter (OTC) to public. In terms of market perfomance, XRP currently stands 2.7% above its value 30 days ago, though it has declined 2.7% over the past day and 25.3% over the past week.

XRP is regarded as one of the so-called ‘dinosaur coins’ that awakened from market dormancy at the close of 2024. Year-to-date, XRP remains 12.5% higher, and over the past six months, it has appreciated more than 300% against the U.S. dollar.

XRP price on South Korea’s Upbit on Feb. 6, 2025.

Moreover, while XRP trades at $2.34 on Bitstamp at 7:30 p.m. ET on Thursday evening, it is exchanging hands for $2.53 on Upbit, reflecting an 8.12% premium. Additionally, XRP is the top trading coin on both Upbit and Bithumb, the two leading crypto exchanges in South Korea.

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