The latest application documents for the XRP ETF submitted to the U.S. Securities and Exchange Commission (SEC) explicitly warn for the first time that “Whale manipulation” could have a significant impact on the XRP market. The Cyber Hornet S&P500/XRP ETF prospectus candidly points out that the supply of XRP is highly concentrated in the hands of a few large holders, and the trading behavior of these “Whales” may lead to severe market fluctuations and pose a threat to overall stability.

(Source: SEC)
The uniqueness of this application document lies in the fact that it represents the first instance of an institutional-level applicant formally acknowledging the existence of “Whale manipulation” in regulatory filings regarding the cryptocurrency market. Cryptocurrency legal expert Bill Morgan stated that this document is of milestone significance, as it officially brings into regulatory focus the risks that have long been discussed quietly within the crypto community.
“When institutional investors acknowledge whale manipulation risks in the formal documents submitted to the SEC, this should be regarded as a real issue that requires attention,” Morgan pointed out while analyzing the document. “Many traders are accustomed to attributing market fluctuations to broader market forces or natural speculative behavior, but this document indicates that institutional participants have recognized deeper structural issues.”
The ETF application document also elaborates on how the unique supply structure of XRP may exacerbate this risk:
· The total supply of XRP was fully created at the time of issuance.
· Cannot expand supply through mining or staking like Bitcoin or Ethereum.
· Validators do not need to issue new coins to maintain network security.
· This fixed supply structure may lead to greater liquidity challenges.
This design creates a fundamental difference in the supply and demand dynamics of XRP compared to other mainstream crypto assets, especially when facing changes in market demand, the lack of a natural supply expansion mechanism may lead to more severe price fluctuations.
The emergence of this document may mark an important step towards greater transparency in the cryptocurrency market. By publicly acknowledging the risks of “Whale manipulation,” ETF applicants not only raise investors' awareness of potential risks but may also prompt regulators to pay more attention to the concentration issues in the cryptocurrency market.
Morgan further pointed out: “If investors are unwilling to acknowledge the potential risks of manipulation in the cryptocurrency market, then they should seriously consider whether it is appropriate for them to participate in this field. Transparency and risk awareness are the foundation for the healthy development of the market.”
As the number of cryptocurrency ETF applications continues to rise, such risk disclosures may become a standard element in future applications, helping to establish a more mature and transparent market environment. For XRP investors, understanding these structural risks is crucial, especially when considering long-term holding strategies.
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