- CBOE filed a 19b-4 form for the Canary PENGU ETF, aiming to list a fund holding Solana-based meme coin PENGU and Pudgy Penguin NFTs.
- The fund will hold 80–95% in PENGU and 5–15% in NFTs, with minimal ETH and SOL used strictly for transactions.
- PENGU is now only the second meme coin with a proposed ETF, following Dogecoin, but Canary remains the sole firm pushing a PENGU product.
The CBOE has officially submitted its 19b-4 form to the SEC to list and trade the Canary PENGU ETF, marking a major milestone in bringing meme coin investments to institutional investors. This move follows Canary Capital’s earlier S-1 filing and positions PENGU as only the second meme coin ETF proposal after Dogecoin.
ETF Structure and Asset Allocation
According to the filing, the PENGU ETF will invest primarily in PENGU tokens and Pudgy Penguin NFTs, allocating between 80% to 95% of its assets to PENGU and 5% to 15% to NFTs. However, Canary Capital clarified it aims to hold at least 95% of the fund in just those two assets. Small portions of SOL and ETH will also be held to cover transaction fees and NFT purchases, but only as needed, not for investment exposure.
Because PENGU operates on the Solana network and Pudgy Penguin NFTs reside on Ethereum, ETH and SOL will be used for auction payments and gas fees related to buying or selling fund assets. Still, the firm emphasized these holdings are purely operational.
Competitive Landscape and SEC Approval Path
If approved, the PENGU ETF will be a trailblazer in Solana-based meme coin exposure through a regulated investment vehicle. Currently, DOGE is the only other meme coin with a 19b-4 form under SEC review. While several major firms—like Grayscale, Bitwise, and 21Shares—are racing to secure approval for DOGE ETFs, Canary Capital stands alone in its pursuit of PENGU.

The ETF not only gives exposure to the meme coin but also taps into NFT enthusiasm, merging two explosive sectors in one investment product. The SEC’s decision on this innovative ETF could signal how open regulators are to broader meme asset adoption.