PENGU Spot ETF: A bold move for NFT investing — or just hype?

January 2024 marked a pivotal point in the crypto industry: the US Securities and Exchange Commission (SEC) approved a bunch of Bitcoin (BTC) Spot exchange-traded funds (ETFs) after a decade of resisting it. Later that year, several Ethereum (ETH) Spot ETFs were also approved. These early successes encouraged investment funds focused on digital assets to seek approvals for other altcoins, as ETF applications for Dogecoin (DOGE), Polkadot (DOT), Solana (SOL), Avalanche (AVAX) and other high-cap cryptos have ended up on the SEC's desk in recent months.

Until Mar 20, 2025, one thing had never occurred: an NFT-based crypto ETF application. Such a move was thought to border on impossibility, given how stringently and at length the SEC evaluated ETF applications even for established fungible cryptos. And yet, the Canary Capital investment manager submitted an application to the SEC for approval of the first NFT-focused crypto ETF product, the PENGU Spot ETF, triggering a mini-revolution in the emerging space at the junction of crypto and traditional finance.

If approved, this ETF will be the first of its kind in the industry, based on a mix of PENGU tokens and Pudgy Penguins NFTs. Many observers expect Canary Capital to struggle mightily for SEC endorsement of its revolutionary product. Nevertheless, the SEC now has a track record of approving crypto ETFs — which raises hopes for both the altcoin ETFs mentioned above and the PENGU Spot ETF application.

Key Takeaways:

• The proposed PENGU Spot ETF is an exchange-traded fund based on the PENGU token and the Pudgy Penguins NFTs. Its provider, Canary Capital, lodged an application for its approval with the US SEC on Mar 20, 2025. As of early April 2025, the regulator has yet to consider the application.

• Canary Capital's application has historical significance as the first instance of an NFT-based ETF product submitted for approval to the SEC. It's also the first ETF that includes a relatively small-cap cryptocurrency as a significant element.

What is the PENGU Spot ETF?

The PENGU Spot ETF is a proposed exchange-traded fund (ETF) product introduced by the Canary Capital investment management firm, and is currently awaiting approval by the SEC. Canary Capital submitted the application on Mar 20, 2025, making this the first crypto ETF product with an NFT component that’s vying for the approval of America's primary financial regulator. The ETF has been registered in the US state of Delaware.

The Pengu Spot ETF's portfolio is envisioned as consisting primarily of PENGU tokens that will make up anywhere between 80% and 95% of total assets held, with the rest allocated to Pudgy Penguins NFTs. Small portions of Solana's SOL coins and Ethereum's ETH tokens will also be included in order to facilitate transactions and liquidity support, as PENGU tokens are mainly issued on the Solana blockchain, and Pudgy Penguins NFTs are an Ethereum-based collection. 

Since Canary Capital will hold these assets and periodically rebalance the portfolio, gas fee payments on Solana and Ethereum will apply, with fees paid in SOL and ETH, respectively.

Launched in 2021 on Solana, the Pudgy Penguins NFT collection consists of 8,888 items, each depicting a cute penguin with a distinct combination of five different traits. In December 2024, the project introduced a related fungible cryptocurrency, the Ethereum-based PENGU token. As of Apr 2, 2025, PENGU is a smaller-cap asset, ranked 191st in the crypto market, with a total market cap of $319 million. In contrast, Pudgy Penguins are among the leading projects in the NFT space, ranked second among all NFT collections, with a market cap of $155 million.

Source: dappradar.com

Canary Capital's application to the SEC is unique in two ways: it’s the first ETF with an NFT component, and it marks the first time ETF approval has been sought for a relatively smaller-cap cryptocurrency, PENGU, which isn’t even among the top 100 crypto assets by market cap. All of the other crypto ETF applications approved by the SEC (or currently vying for approval) are based on high-cap, leading assets that are typically ranked within the top 30.

Current landscape of the PENGU Spot ETF

As of Apr 2, 2025, the SEC has had the application for the PENGU Spot ETF application for just two weeks. The regulator has up to 240 days to review such applications, although historically, the SEC has pondered over crypto ETF applications for years. Now, however, the string of Bitcoin and Ethereum Spot ETF approvals in 2024 raises hopes that newer submissions may be subject to an already established evaluation framework — and thus greenlighted much faster.

At the moment, the SEC is also considering spot ETF applications for several high-cap cryptocurrencies, including Dogecoin, Solana, Polkadot, Litecoin (LTC) and XRP (XRP). If the regulator decides to approve the applications in batch mode — all or several at once — Canary Capital will have reason to hope that its ETF is included.

However, there's been skepticism regarding the PENGU Spot ETF application, with some analysts believing that its chances might differ from those of the larger, more established altcoin ETFs. This isn't surprising, as a PENGU Spot ETF would be a distinct product, being the first NFT-focused ETF. In addition, NFTs have more limited liquidity than fungible cryptocurrencies. 

NFTs may also be harder to valuate objectively. The prices of fungible cryptos are easily sourced from the crypto market, where supply and demand establish their value. In contrast, the limited liquidity and uniqueness of NFTs makes it much harder to price them efficiently.

Moreover, the PENGU token — which will make up most of the proposed ETF — isn't among the most traded assets in the crypto market. Because PENGU has a modest position in the crypto space (along with its origins as a meme coin), the SEC could view it with more skepticism than it does the leading altcoins.

Naturally, all these factors are just speculation at this point, and we’ll need to wait on the SEC’s initial comments regarding the first NFT-based ETF under their consideration in order to form a more defined view of the product's prospects for approval.

Current impact of the PENGU Spot ETF application on the crypto market

The news of the PENGU Spot ETF application has so far had no appreciable impact on the price of the PENGU token itself. On the day of the application (Mar 20, 2025), the token was trading at around $0.007. Two weeks later, it's still hovering around the same price. 

On the other hand, there's been a modest increase in the average price of Pudgy Penguins NFTs traded on the market: between March 20 and 28, the average price rose by 16% from around $16,450 to $19,120, though it has since retraced slightly to $17,490 as of Apr 2.

Given the modest price effect, investors are likely still cautious about the chances for the PENGU Spot ETF's approval.

However, if it is approved, the broader impact on the crypto market could be far-reaching, as such a step would signify the SEC's openness to both NFT-based ETFs, and ETFs made up of smaller-cap cryptocurrencies, including meme coins. The number of tokenized asset funds that offer NFT-based products would then be likely to increase significantly, facilitating mainstream NFT adoption within traditional financial markets.

Further altcoin spot ETF prospects

An SEC approval of the PENGU Spot ETF may lead to a flurry of further ETF applications based on NFTs in some form. This could even include the first ETFs composed entirely of NFTs. Other crypto asset types — e.g., real-world assets (RWAs) — may also become candidates for the SEC’s consideration. Furthermore, in the unlikely event that Canary Capital’s PENGU Spot ETF were to be approved ahead of the altcoin spot ETFs currently in the SEC’s pipeline, it would send a very strong signal that those ETF applications are also a sure bet.

The bottom line

The current PENGU Spot ETF application is a pioneering event that may open up opportunities for NFT ETFs and other crypto ETFs based on partial NFT holdings. Although the SEC approved multiple Bitcoin Spot ETFs in early 2024, few people expected an NFT-based ETF to emerge so soon afterward. Probably even fewer expected a meme coin–based ETF to be taken seriously by the SEC. Unique in so many ways, the PENGU ETF flips the entire concept of traditional ETFs on its head.

Canary Capital's attempt to get approval for an NFT-backed ETF is truly a bold undertaking, though observers said the same thing about Bitcoin ETFs just a few years ago. Someone needed to become a trailblazer in this area — and Canary Capital has taken up the noble role without hesitation. Now, all eyes are on the SEC as it prepares to weigh in on a product it has never before encountered.

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