BlackRock Submits Third Bitcoin Spot ETF Filing: Why It Has Not Included Solana and XRP In Its Current Product Lineup
? BlackRock’s Third Filing: A Critical Milestone for Institutional Crypto Positioning
In Q3 2024, BlackRock, the world’s largest asset manager, filed its third U.S. spot bitcoin ETF application with the SEC, just 14 months after its first ever bitcoin ETF filing. While many market observers initially framed this as a routine move to capture market share, the filing represents a deliberate strategic lock-in of compliant pathways for crypto assets: its first two filings helped lift market expectations for spot bitcoin ETF approval odds from less than 10% to nearly 90%, with each submission signaling strong institutional demand for regulated crypto products. BlackRock’s already approved spot bitcoin ETF now holds more than $30 billion in assets, accounting for nearly 40% of total market share. This newest product is targeted exclusively at long-duration capital pools like pension funds and family offices, with a fee 15 basis points lower than its existing offering, designed to win large, long-term allocation mandates rather than serve high-frequency retail trading demand.
? The Absence of Solana and XRP: Compliance Guardrails, Not Value Rejection
This latest filing’s underlying asset pool remains limited exclusively to bitcoin, with no inclusion of top-10 market cap assets Solana and XRP, a choice that sparked widespread community debate. Many crypto content creators have framed this exclusion as BlackRock writing off the long-term value of Solana and XRP, but the decision is entirely a proactive risk-mitigation move within existing regulatory frameworks. Solana has not yet cleared the SEC’s security classification review process, while XRP remains locked in a three-year ongoing legal dispute with the agency. Even the 2023 preliminary ruling in XRP’s favor left significant legal ambiguity around its regulatory status, and including it in an ETF would trigger material security classification risk — a line the $10+ trillion asset manager will never cross.
⚡️ Solana’s Barriers to Inclusion: Dual Technical and Compliance Thresholds
Solana is one of the most active layer-1 blockchains in the market today, ranking among the top for DeFi total value locked and NFT trading volume, with a market cap that once reached the global top 5 for crypto assets. Its average daily on-chain transaction count is more than 3 times that of Ethereum, and over 60% of its user base is younger, making it the primary on-ramp for Gen Z crypto participation. Many retail users argue Solana’s technical performance outpaces Ethereum and its ecosystem momentum rivals bitcoin, so it should be a core institutional holding, but institutional asset screening logic is fundamentally different from retail priorities. First, assets must be confirmed not to qualify as securities; second, they must pass extreme market stress stability tests. Solana has suffered multiple network-wide outages in recent years, and even outages lasting less than 4 hours are enough to be rejected by institutional risk teams, as long-duration capital cannot absorb asset losses from technical failures.
? XRP’s Compliance Deadlock: A Court Win Does Not Equal Full Regulatory Clarity
The XRP community has long celebrated the 2023 preliminary court ruling as a landmark victory, arguing that public exchange trading of XRP does not constitute an unregistered securities offering, and that the asset meets ETF inclusion criteria. Many XRP supporters frame BlackRock’s delayed XRP ETF filing as biased against the project, but the SEC is still appealing the ruling, with the full legal process not expected to conclude until 2025. Until a final, binding ruling is in place, no asset manager will dare add XRP to a spot ETF underlying pool. Industry data shows XRP now has over 100 million global users, with cross-border payment use cases spanning more than 50 countries, and many traditional financial institutions are already testing XRP-based cross-border settlement rails. But with $10+ trillion in assets under management, BlackRock faces far larger potential brand damage from SEC penalties for non-compliant underlying assets than any fee revenue it could generate from an XRP-focused product.
? BlackRock’s Crypto Playbook: Only Zero-Risk Compliant Products
From its first bitcoin ETF filing in 2023 to its third submission today, BlackRock’s entire crypto product portfolio is built exclusively around bitcoin, with no forays into altcoin categories. Many market participants argue that as the world’s largest asset manager, BlackRock should capture opportunities across every crypto vertical to offer clients a full suite of crypto allocation options, but the firm’s crypto business has been built from day one around a core mandate of “zero compliance risk”. Its target clients are traditional institutions looking to add crypto as a broad asset class, and these clients prioritize regulatory certainty and asset safety far more than short-term yield. So even if Solana and XRP offer materially higher long-term upside than bitcoin, they will not be added to BlackRock’s product lineup until all compliance risks are fully eliminated.
? Key Takeaways for Retail Investors
Many retail investors have rushed to sell their altcoin holdings after seeing Solana and XRP excluded from BlackRock’s latest ETF filing, treating the firm’s asset selection as a definitive value judgment on individual projects. Many now treat BlackRock’s ETF underlying pool as a “crypto project value ranking”, assuming assets excluded from the pool have no long-term investment merit, but this is purely a commercial choice aligned with current regulatory frameworks, with no direct bearing on a project’s intrinsic growth value. For example, Solana’s rapid technical iteration, vibrant ecosystem, and long-term price elasticity may outperform bitcoin, but it is temporarily excluded from mainstream institutional product pools solely due to unresolved compliance issues. Overall, each BlackRock SEC filing pushes the boundaries of U.S. crypto regulation forward, even if this submission does not cover more tokens, it lays critical groundwork for industry-wide compliance. As U.S. regulatory guidance for altcoins becomes clearer and legal disputes are fully resolved, BlackRock will likely add leading assets like Solana and XRP to its product lineup over time; current exclusion is a temporary, stage-specific choice, not a permanent value rejection. The long-term value of the crypto industry is rooted in technical innovation, ecosystem growth, and real user demand, and retail investors should distinguish between institutional compliance choices and a project’s intrinsic value, avoiding blind herding to institutional moves or letting single market headlines skew long-term judgment.
