CTF Written Submission
Re: Crypto Exchange-Traded Products
May 8, 2025
- The Commission should adopt clear, evidence-based standards for reviewing crypto-asset based ETPs, focusing on the size and liquidity of the underlying spot market rather than the existence of a surveillance-sharing agreement (SSA) or a regulated market.
- Market capitalization and the number of active spot markets should be prioritized as the most significant factors in evaluating crypto assets for ETP listing.
- The historical track records of ETFs registered under the Investment Company Act that obtain exposure to the same assets as a proposed ETP should be highly instructive to the Commission.
Last Reviewed or Updated: May 9, 2025