Grayscale Investments has made a strategic move by submitting an S-1 registration statement to the U.S. Securities and Exchange Commission (SEC) on August 25 for the Grayscale Avalanche Trust (AVAX).
The Detailed Look into Grayscale’s AVAX ETF Submission
This submission outlines the basic framework of the ETF’s structure and pricing objective. Grayscale aims for the Grayscale Avalanche Trust product to directly track the price of AVAX coin, thereby enabling investors to engage directly with the native mainnet asset of the Avalanche network.
The ETF is set to be directly listed on Nasdaq, a move that underscores Grayscale’s objective of gaining stock exchange listing status for the investment product. Coinbase Custody is responsible for the custody services of the AVAX coins held on behalf of the ETF’s clients, with Coinbase taking up the primary brokerage role.
What Lies Ahead: The Process Unfolds
Following Grayscale’s application to the SEC, the process begins with the review of the S-1 file. After the review, the commission will send a comment letter, to which Grayscale will respond with S-1/A amendments. These correspondences may occur over several rounds. Upon completing the initial review phase, the issuer may expedite the process by requesting acceleration under Rule 461, subject to SEC approval. Concurrently, a Nasdaq listing application will be submitted, along with the ETF’s symbol reservation, form completions, fees, and corporate governance verifications. If the product has a structure beyond existing exchange rules, Nasdaq will propose a Rule 19b-4 rule change to the SEC. This proposal will call for public commentary and yield either approval or denial.
Pre-trade, CUSIP and DTC (DTCC) compliance will be ensured, with clearing-storage flow and market opening plans set in motion. Once the S-1 becomes effective, the Nasdaq listing is approved, and if necessary, the 19b-4 is enacted, the trade date for the ETF will be announced, followed by the commencement of trading activities.
The S-1 review typically spans 90–150 days. Most filings receive the first comment letter within 27–30 days. With minimal comments and swift responses, it’s practically feasible for the application to become effective within about 6–8 weeks via Rule 461 acceleration. However, if a 19b-4 is needed for ETF/ETP listing, the process may extend up to 240 days from Federal Register publication for a final decision. The SEC has an initial 45-day window to decide or extend the timeframe.
