Bitcoin ETF hopefuls amend filings as SEC decision looms

A decision on bitcoin ETFs looms, with the Ark 21 Shares deadline on its proposed spot bitcoin ETF coming up on Jan. 10. 

Ahead of any potential decision by the Securities and Exchange Commission, the final 11 filers are submitting last-minute details through required filings. In amended registration statements known as S-1s on Monday, multiple firms revealed — some for the first time — their fees and authorized participants, or APs.

A slew of potential issuers filed amended S-1s in late December, listing authorized participants and fees for the first time. However, the Monday updates put fierce fee competition on full display — with multiple firms trying to come in lower than competitors and some even lowering their fees. 

The amendments also finalize the most popular companies named as APs. 

Read more: Fees, seeds and APs: What we know — and don’t know — about the planned bitcoin ETFs

An AP is an entity that can create and redeem shares of an ETF. The shares can then be exchanged for either a basket of securities reflecting the holdings of the ETF or for cash.

Last week, exchanges — on behalf of the proposals — filed amended 19b-4s, indicating that 11 firms are aiming to get approval for their proposed ETFs.

Here’s what the amendments are telling us ahead of a potential decision.


BlackRock is ready to play ball when it comes to fees, disclosing a planned fee of 0.20% (20 basis points) for the first 12 months, or $5 billion in assets. The fee will then rise to 30 basis points. 

As previously disclosed, the firm plans to tap Jane Street and JPMorgan Securities. However, the Jan. 8 filing also lists Macquarie Capital and Virtu Americas as APs. The filing states that BlackRock can name additional authorized participants “at any time.”

Ark Invest, 21Shares

The firms’ proposed ETF — a refiling after a previously proposed ETF was denied by the SEC — shows that the partner companies are on the lower end of fees. 

The Jan. 8 filing reveals that Ark and 21Shares plan to charge a fee of 25 basis points — a much lower fee than the previously proposed fee of 80 basis points. Additionally, it plans to waive the fee for either the first six months or the first $1 billion of trust assets. 

The Ark 21Shares Bitcoin ETF, if approved, would have Jane Street, Macquarie Capital and Virtu Americas as its APs. 


Unlike Ark and 21Shares, Grayscale didn’t undercut any competitors on the fee front. In fact, the firm has the highest fee of any proposed bitcoin ETF, at 1.5%. 

It’s important to note that Grayscale is one of the outliers (the other being Hashdex) that’s seeking to convert its Bitcoin Trust to an ETF. The firm attempted to file for such a conversion previously, but was denied by the SEC.

However, a panel of judges sided with Grayscale and ordered the SEC to reconsider the application. Notably, however, this doesn’t mean that the SEC has to approve the application. 

Grayscale, in its registration statement known as an S-3, said it would be tapping Jane Street, Virtu, Macquarie Capital  and ABN AMRO as APs. While the latter two firms are new additions, Grayscale previously alluded to tapping both Jane Street and Virtu, with CEO Michael Sonnenshein posting on X that it has had APs lined up “since 2017.”


Bitwise is so far offering the lowest planned fees for its proposed bitcoin ETF, at 24 basis points. It also plans to waive that fee for the first six months or $1 billion, following similar moves from BlackRock, as well as Ark and 21Shares.

The proposed ETF, which would list on the New York Stock Exchange, will tap Jane Street, Macquarie Capital and Virtu Americas as APs. 

At the end of December, the company revealed $200 million in seed capital, which is used to fund the creation units of the ETF so that shares can be offered and traded. 

The most recent filing says, “Pantera Capital Management LP, through one or more of its affiliated investment funds, has indicated an interest in purchasing an aggregate of up to $200 million of Shares in this offering from Authorized Participants or in the marketplace through broker-dealers.”

It notes, however, that Pantera could opt to not purchase shares or could increase its purchase. 


VanEck’s proposed fee is on the lower end, with the investment fund manager revealing a 0.25% fee. Aside from being competitive with a lower fee, the firm has also shown its intent to be active when it comes to marketing. Although it’s not the first to do so, the firm released a teaser for a bitcoin ETF commercial earlier this month.

The company plans to list its ETF on Cboe, similar to the Ark 21Shares Bitcoin ETF, and announced Jane Street, Virtu Americas, ABN AMRO as authorized participants.

“Total proceeds to the trust from the sale of the seed creation baskets were $72,500,000, which resulted in the trust receiving [1,640 BTC],” the filing said.


The traditional finance fund manager followed a number of other firms in tapping Jane Street, Macquarie Capital and Virtu Americas as APs. It previously disclosed Jane Street in that role.

The funds fee is slightly higher than some of its competitors at 50 basis points. 

Invesco Galaxy

Invesco and Galaxy Digital filed jointly for a spot bitcoin ETF. The proposed fee on that fund is slightly higher than that of WisdomTree, at 59 basis points. However, the firm is using tactics similar to Ark, 21Shares and Bitwise in offering a waived fee for the first six months, or the first $5 billion of assets.

Invesco previously named JPMorgan Securities and Virtu. The newest amendment also taps Jane Street and Marex.


Prior to the newest amendments, Fidelity had the lowest fee at 39 basis points. But with four of the 11 potential applicants listing fees below 30 basis points, the financial services giant was pushed to the middle of the pack.

Jane Street and JPMorgan were the first firms named as APs by the company, though the Monday filing also adds Macquarie Capital and Virtu Americas.


The firm has one of the highest fees, at 80 basis points. This previously matched Ark’s fee prior to the Cathie Wood-led company lowering it to 0.25%.

Unlike many of the names on the list, the company did not opt to add additional APs, instead sticking to Jane Street and Cantor Fitzgerald as previously disclosed. 

Franklin Templeton

The proposed ETF from Franklin Templeton discloses a 0.29% fee, putting it in the lower end of fees — excluding the waivers. 

It was also one of the few that didn’t initially disclose APs at the end of December. However, the Monday filing shows the firm plans to tap Jane Street and Virtu Americas.


While Hashdex didn’t issue an amended S-1 on Monday, the company was included in the Friday round of 19b-4s filed by exchanges. The potential ETF issuer will tap Jane Street, Virtu and Mirae as authorized participants, a person familiar with Hashdex’s proposal told Blockworks. 

A company spokesperson declined to comment. 

Ben Strack contributed reporting.

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