Nasdaq has submitted a 19b-4 filing to the Securities and Exchange Commission (SEC) to list and trade shares of the Grayscale Hedera Trust (HBAR), marking another step toward expanding cryptocurrency-based exchange-traded funds (ETFs). The move signals increasing momentum for alternative cryptocurrency ETFs beyond Bitcoin and Ethereum, as analysts predict greater approval odds for altcoins.
The filing follows Nasdaq’s recent submission of a 19b-4 for Canary Capital’s spot HBAR ETF, further advancing the case for Hedera-based investment products. Bloomberg Senior ETF Analyst Eric Balchunas previously noted that among the growing list of altcoin ETF applications, Hedera and Litecoin ETFs stand the strongest chance of securing SEC approval.
Grayscale’s Hedera Trust Structure
Grayscale’s Hedera Trust is structured as a commodity-based trust, operating under Nasdaq Rule 5711(d). The trust’s assets consist solely of HBAR, the native token of the Hedera Network. Each share represents a proportional interest in the trust’s HBAR holdings, adjusted for expenses and other liabilities. Unlike traditional investment funds, the trust is not actively managed and does not engage in market-making strategies.
The trust will use the CoinDesk HBAR CCIXber Reference Rate to calculate the net asset value (NAV) of its holdings. Coinbase Custody Trust Company, LLC will serve as the custodian, with BNY Mellon Asset Servicing acting as the administrator and transfer agent. Marketing and distribution responsibilities will be handled by Foreside Fund Services, LLC.
Hedera is a decentralized public network utilizing the Hashgraph consensus algorithm to facilitate transactions. It differs from traditional blockchain networks by employing a gossip-about-gossip and virtual voting mechanism to confirm transactions with finality. The network is governed by the Hedera Governance Council, a consortium of prominent companies, including Google and IBM, responsible for managing software updates, token distribution, and compliance.
As of February 2025, the Hedera Council held approximately 10.62 billion HBAR, or 21.25% of the total supply, with the Hedera Foundation receiving a 7 billion HBAR grant in December 2024. Roughly 83.8% of the total HBAR supply is currently in circulation.
Regulatory Landscape and SEC Filings
The 19b-4 submission is the second step in the SEC’s approval process for ETFs. Once acknowledged, the proposal will be published in the Federal Register, opening a window for regulatory review. The latest filings reflect a growing industry push for altcoin ETFs following the reelection of former President Donald Trump, with market participants anticipating a more crypto-friendly SEC.
Recent weeks have seen filings for spot ETFs linked to Solana, XRP, Cardano, Litecoin, and Dogecoin. On the same day as Nasdaq’s Grayscale Hedera filing, the New York Stock Exchange submitted a 19b-4 for Bitwise’s Dogecoin ETF. Bloomberg analysts estimate that Litecoin ETFs hold a 90% chance of approval, while Dogecoin ETFs have a 75% probability.
