Grayscale Solana Trust Eyes NYSE Arca Listing, Awaiting SEC Nod

TL;DR

**Grayscale's Solana ETF is a high-stakes bet on regulatory approval, and until the SEC gives the green light, it's all talk and no trade.**

AI Summary

Grayscale Solana Trust (SOL) filed an S-1/A on August 29, 2025, to register an indeterminate number of Shares for listing on NYSE Arca under the ticker GSOL, aiming to convert its existing OTCQX product into a spot Solana ETF. The Trust's objective is for its Shares to reflect the value of SOL held, less expenses, providing investors with exposure to Solana. Currently, the Trust only supports 'Cash Orders' for creation and redemption, where Authorized Participants deposit or receive cash, and a third-party Liquidity Provider handles SOL exchange. The filing explicitly states that the 19b-4 Application for NYSE Arca listing, filed on December 3, 2024, has not yet been approved by the SEC, and the Trust will not seek effectiveness until such approval is obtained. The Trust also notes the potential for future in-kind creations and redemptions, subject to NYSE Arca obtaining 'In-Kind Regulatory Approval' following recent SEC approvals for other spot digital asset ETPs. The Trust is an 'emerging growth company' and intends to rename itself 'Grayscale Solana Trust ETF' upon the registration statement's effectiveness and NYSE Arca listing.

Why It Matters

This S-1/A filing is a critical step for Grayscale Solana Trust (SOL) to transition from an OTC product to a spot Solana ETF on NYSE Arca, potentially opening up SOL exposure to a broader institutional and retail investor base. Approval would intensify competition in the digital asset ETP market, particularly against any future spot SOL ETFs, and could significantly impact the liquidity and price discovery of Solana. For investors, it offers a regulated, accessible vehicle for SOL exposure, but the current cash-only creation/redemption mechanism could lead to wider tracking errors compared to in-kind models. Employees and customers of Grayscale and its service providers like Coinbase, Inc. and The Bank of New York Mellon would see increased activity and potential growth if the ETF launches.

Risk Assessment

Risk Level: high — The filing explicitly states, "As of the date of this filing, the 19b-4 Application has not been approved by the SEC. The Trust makes no representation as to when or if such approval will be obtained." This regulatory uncertainty is a primary risk. Furthermore, the Trust's inability to facilitate in-kind creations and redemptions, as noted by "the Trust is not at this time able to create and redeem shares via in-kind transactions with Authorized Participants," introduces liquidity risks and potential for wider spreads between NAV and market price.

Analyst Insight

Investors should closely monitor SEC announcements regarding the 19b-4 Application for Grayscale Solana Trust (SOL) and any developments on in-kind creation/redemption approvals. Until regulatory clarity emerges, consider the current GSOL shares on OTCQX as a speculative play with significant premium/discount risk. For those seeking Solana exposure, direct SOL ownership or other regulated avenues might offer more predictable pricing and liquidity in the interim.

Financial Highlights

debt To Equity

0.0

revenue

$0

operating Margin

0%

total Assets

$0

total Debt

$0

net Income

$0

eps

$0

gross Margin

0%

cash Position

$0

revenue Growth

+0%

Key Numbers

• 10,000 Shares — Basket Size (Minimum block of Shares for creation and redemption)
• December 3, 2024 — 19b-4 Application Filing Date (Date NYSE Arca filed for listing approval with the SEC)
• August 29, 2025 — S-1/A Filing Date (Date of the current amendment filing)
• Rule 19b-4 — SEC Rule (Rule under which NYSE Arca filed for listing approval)
• Rule 415 — SEC Rule (Rule for delayed or continuous offerings)

Key Players & Entities

• Grayscale Solana Trust (SOL) (company) — Registrant and issuer of Shares
• Grayscale Investments Sponsors, LLC (company) — Co-Sponsor of the Trust
• NYSE Arca, Inc. (company) — Intended listing exchange for the Shares
• Securities and Exchange Commission (regulator) — Approves or disapproves the 19b-4 Application and registration statement
• Edward McGee (person) — Chief Financial Officer of Grayscale Investments Sponsors, LLC and Agent For Service
• Coinbase, Inc. (company) — Prime Broker of the Trust
• Coinbase Custody Trust Company, LLC (company) — Custodian of the Trust
• The Bank of New York Mellon (company) — Transfer Agent and Administrator of the Trust
• Davis Polk & Wardwell LLP (company) — Legal counsel for the filing
• Solana Network (company) — Blockchain network underlying the SOL digital asset

FAQ

Risk Factors

• SEC Approval Uncertainty [high — regulatory]: The Trust's listing on NYSE Arca is contingent upon the SEC's approval of the 19b-4 Application filed on December 3, 2024. The Trust will not seek effectiveness of its registration statement until this approval is obtained, creating uncertainty regarding the launch of the spot Solana ETF.
• Solana Price Volatility [high — market]: The Trust's Shares are designed to reflect the value of SOL, which is subject to significant price volatility. Fluctuations in the price of SOL could materially impact the value of an investment in the Trust's Shares.
• Reliance on Third-Party Liquidity Provider [medium — operational]: Currently, the Trust relies on a third-party Liquidity Provider to handle the exchange of SOL for 'Cash Orders' during creation and redemption. Any disruption or failure by this provider could impact the Trust's ability to operate efficiently.
• Potential for Future In-Kind Approvals [medium — regulatory]: While the Trust currently supports 'Cash Orders,' it notes the potential for future in-kind creations and redemptions, subject to 'In-Kind Regulatory Approval' from NYSE Arca. The timeline and certainty of obtaining this approval are not specified.
• Tax Consequences [medium — legal]: The filing outlines material U.S. federal income tax consequences for investors. Investors are advised to consult their own tax advisors, as the tax treatment of digital assets and related trusts can be complex and subject to change.
• Competition in Digital Asset ETFs [medium — market]: The Trust operates in an evolving market for digital asset ETFs. The success of the Grayscale Solana Trust ETF may be affected by the performance and offerings of other existing and future digital asset investment products.
• Emerging Growth Company Status [low — operational]: The Trust is classified as an 'emerging growth company,' which may allow for reduced disclosure requirements. This status could impact the level of detail available to investors regarding the Trust's operations and financials.
• Information Reliability [low — legal]: The Trust states that it has not authorized anyone to provide information other than what is contained in the prospectus and takes no responsibility for information provided by others. Investors must rely on their own examination of the Trust and the SOL market.

Industry Context

The digital asset ETF market is rapidly evolving, with increasing institutional interest and regulatory scrutiny. Following approvals for Bitcoin and Ethereum ETFs, Solana is positioned as the next major digital asset to potentially gain ETF status. However, the landscape is competitive, with multiple issuers vying for market share and investor capital.

Regulatory Implications

The conversion to a spot Solana ETF hinges on SEC approval of the 19b-4 filing. Any delays or denials could significantly impact the Trust's strategy and investor sentiment. The ongoing evolution of digital asset regulation presents both opportunities and risks for such products.

What Investors Should Do

1. Monitor SEC Approval Status
2. Assess Solana's Volatility
3. Review Fee Structure
4. Understand Creation/Redemption Mechanism

Key Dates

• 2024-12-03: 19b-4 Application Filing Date — NYSE Arca filed for listing approval with the SEC, a crucial step towards the ETF conversion.
• 2025-08-29: S-1/A Filing Date — Grayscale filed the amended registration statement, updating details for the proposed spot Solana ETF.

Glossary

Shares

Units of ownership in the Grayscale Solana Trust. (Represents the investment vehicle for investors seeking exposure to SOL.)

SOL

The native cryptocurrency of the Solana blockchain. (The underlying asset whose value the Trust aims to track.)

Spot Solana ETF

An Exchange Traded Fund that holds Solana directly and aims to track its real-time market price. (The intended structure of the Grayscale Solana Trust upon SEC approval and listing.)

S-1/A

An amendment to a registration statement filed with the SEC, typically used to update information before a securities offering becomes effective. (Indicates the Trust is actively seeking to convert to an ETF and is providing updated disclosures.)

19b-4 Application

A filing with the SEC by a national securities exchange (like NYSE Arca) to propose a new rule or rule change, in this case, for listing a new security. (This application is critical for the ETF's listing approval on NYSE Arca.)

Cash Orders

A method for creating or redeeming ETF shares where Authorized Participants deposit or receive cash, rather than the underlying assets. (The current mechanism for the Trust, requiring a third party for SOL exchange.)

In-Kind Creations and Redemptions

A method for creating or redeeming ETF shares where Authorized Participants exchange the underlying assets (SOL) directly for ETF shares, and vice versa. (A potential future capability for the Trust, subject to regulatory approval.)

Authorized Participant

A financial institution that has entered into an agreement with an ETF sponsor to facilitate the creation and redemption process of ETF shares. (Key intermediaries in the ETF's operational flow.)

Year-Over-Year Comparison

As this is an S-1/A filing for a proposed ETF conversion, there is no direct prior filing with comparable financial metrics (revenue, net income, margins) to compare against. The key changes revolve around the regulatory process for listing on NYSE Arca and the transition from an OTCQX product to a potential spot ETF structure.

Key Financial Figures

• $2.8 billion — trading volume of SOL was approximately $2.8 billion. As of June 30, 2025, the aggregate mar
• $82.7 billion — e market value of SOL was approximately $82.7 billion. As of June 30, 2025, SOL was the sixth

Filing Documents

• gsol_s-1_amendment_3.htm (S-1/A) — 2996KB
• sol-ex16_1.htm (EX-16.1) — 6KB
• sol-ex23_1.htm (EX-23.1) — 5KB
• sol-ex23_2.htm (EX-23.2) — 5KB
• img178347043_0.jpg (GRAPHIC) — 51KB
• img178347043_1.jpg (GRAPHIC) — 1196KB
• img178347043_2.jpg (GRAPHIC) — 51KB
• 0001896677-25-000009.txt ( ) — 4799KB

Forward-Looking Statements

Forward-Looking Statements ii Prospectus Summary 1 The Offering 9

Use of Proceeds

Use of Proceeds 61 Management’s Discussion and Analysis of Financial Condition and Results of Operations 62

Business

Business 69 Key Personnel of the Sponsor 104 Certain Relationships and Related Party Transactions 106 Description of the Shares 107 Description of Creation and Redemption of Shares 112 Material U.S. Federal Income Tax Consequences 118 ERISA and Related Considerations 124 Plan of Distribution 126 Legal Matters 128 Experts 129 Where You Can Find More Information 130 Glossary of Defined Terms Index to Financial Statements 131 F- 1 Neither the Trust nor the Sponsor has authorized anyone to provide you with any information other than that contained in this prospectus or any free writing prospectus prepared by or on behalf of the Trust. Neither the Trust nor the Sponsor takes any responsibility for, and can provide no assurance as to the reliability of, any information that others may give you. Neither the Trust nor the Sponsor is making an offer to sell any security or soliciting any offer to buy any security in any jurisdiction where the offer or sale is not permitted. You should not assume that the information appearing in this prospectus or any free writing prospectus is accurate as of any date other than the respective dates on the front of such documents. The Trust’s business, assets, financial condition, results of operations and prospects may have changed since those dates. This prospectus does not constitute an offer to sell, or an invitation on behalf of the Trust or the Sponsor, to subscribe to or purchase any securities, and may not be used for or in connection with an offer or solicitation by anyone, in any jurisdiction in which such an offer or solicitation is not authorized or to any person to whom it is unlawful to make such an offer or solicitation. Authorized Participants may be required to deliver a prospectus when making transactions in the Shares. The information contained in the section captioned “Business—Overview of the SOL Industry and Market” is based on informati

View Full Filing

View this S-1/A filing on SEC EDGAR