The SPY is registering strong downside momentum while price is still above the previous swing low pivot, but we can't say for sure it is a reverse divergence until price proves to hold above the $134.60 range.
One issue of concern would be the proximity of the slow line to zero. The slow line crossing zero typically precedes a 20- & 50-MA cross, however, these two MA's do have a decent distance between each other.
Back to 2011 we saw these two moving averages trending much like they are now and it took 4 instances of the slow line crossing zero before a steep sell-off occurred. The first instance was just a pullback of the trend, but the second and third were momentum events that wore down the trend and the fourth instance was the textbook lower high trend change.
To better visualize the the trend change take a look at a chart with just the moving averages and price removed, notice how the 50-MA flattens out then starts moving lower while the 20-MA corrects into the 50-MA forming the lower high (while on the flip side the reverse happened to start our most recent bullish cycle). So until we see something like this develop I would suggest we're at least months away from a character change if it were to occur.