Subject: SR-CboeBZX-2025-021: Webform Comments from Will Wrighthouse
From: Will Wrighthouse
Affiliation:

Feb. 21, 2025

The SEC should delay approval of an XRP ETF due to the
ongoing legal and regulatory uncertainties surrounding Ripple Labs and
its cryptocurrency, XRP, which create significant risks for investors
and undermine the stability required for a regulated exchange-traded
fund (ETF). Ripple is still navigating a complex legal battle with the
SEC, with Judge Analisa Torres retaining jurisdiction over the case
until August 7, 2025, to ensure compliance with a $125 million penalty
ruling. The SEC's potential decision to drop its appeal or
renegotiate the penalty adds further uncertainty, as the outcome could
reshape the classification of XRP as a security under U.S. law.
This unresolved litigation stems from the SEC's 2020 lawsuit against
Ripple, alleging that XRP sales constituted unregistered securities
offerings. While Judge Torres ruled in 2023 that some XRP sales
violated securities laws, the ambiguity persists regarding XRP's
status-particularly for programmatic sales on exchanges-creating a
regulatory gray area. Approving an XRP ETF prematurely could expose
investors to heightened risks if the SEC's appeal or future rulings
reclassify XRP more broadly as a security, potentially triggering
additional enforcement actions or market instability. This concern is
echoed in web results, such as Bloomberg analyst James Seyffart's
warning that XRP's legal challenges could delay or prioritize other
crypto ETFs, like those for Litecoin, over XRP.
Moreover, the absence of a regulated futures market for XRP, as noted
in Bloomberg's coverage of crypto ETF developments, contrasts with
Bitcoin and Ethereum, which had established futures markets on the
Chicago Mercantile Exchange before their spot ETF approvals.
Additionally, cryptocurrencies like Ethereum, Bitcoin, Litecoin, and
others have futures contracts available on platforms like Coinbase,
providing further market infrastructure to manage risk and volatility,
whereas XRP lacks such offerings. The SEC has historically required
such infrastructure to mitigate manipulation risks, and without it,
approving an XRP ETF could invite regulatory scrutiny or legal
challenges, further complicating the crypto market's maturation. The
web results also indicate that XRP's price volatility and market
sensitivity to legal developments-such as the potential for XRP to
drop below $1.50 or surge to $3.55 depending on SEC actions-heighten
the risk of investor harm if an ETF is approved before these issues
are resolved.
Finally, the SEC's broader 2025 priorities, including crypto
regulation and fiduciary duty, suggest a cautious approach is
warranted. Delaying XRP ETF approval until Ripple's legal battles
are fully resolved and a clearer regulatory framework is established
would align with the SEC's mandate to protect investors and maintain
market integrity, especially in the uncharted territory of
cryptocurrency regulation. This delay would also allow time to assess
the impact of recent legislative changes, such as the SEC Act of 2025
(H.R. 216), which aims to clarify penalty structures for securities
violations, potentially affecting XRP's regulatory status.
By postponing XRP ETF approval, the SEC can ensure that any eventual
decision is grounded in a stable, transparent, and legally sound
foundation, minimizing risks to investors and the broader financial
system.