March 7, 2017
File Number SR-BatsBZX-2016-30
Reasons to reject the proposed rule change:
The biggest beneficiarie for this rule proposed rule changes is the WINKLEVOSS BITCOIN TRUST itself.
- Back in 2013 they silently bought 1% of all bitcoins in existance and in the same year proposed the COIN ETF to pump their investment.
https://www.washingtonpost.com/news/the-switch/wp/2013/11/09/the-11-million-in-bitcoins-the-winklevoss-brothers-bought-is-now-worth-32-million/
- WINKLEVOSS's Bitcoin exchange 'Gemini' is a fiasco, the lowest trading volume of known exhanges. The ETF will use 'Gemini' to track the bitcoin price granting free promotion and reputation to the exchange.
- Gemini is not appropriate to track the price because of its very low volume, USA based GDAX would be a more reasonable choice.
Unprecedent risk not listed in the S-1 filling:
The current team of developers of the Bitcoin reference client and protocol named 'Core' are planning a contentious network split under the name UASF which risks are still unknown to the technical community: https://twitter.com/petertoddbtc/status/839048723430797313
Antpool / Bitmain (Biggest miner and Bitcoin company in the world) CEO about UASF: https://twitter.com/JihanWu/status/837912771832393733
Conflict of interests in Bitcoin development causing the eminent contentious hard fork listed in the S-1 filling:
Blockstream is a relatively new for profit corporation founded by 'Core' developers and that hires all other main 'Core' Bitcoin developers and managed to get rid all original Bitcoin developers. Blockstream was mostly funded by AXA. AXA's CEO Henri de Castries is also the Chairmain of The Bilderberg Group turning Bitcoin pontentially under high pressure of the political and banking elite which interests are unknown. The open source project Bitcoin naturally conflicts with the interests of the Banking sector and political elite and the interests of any for profit corporation like Blockstream.
Other reasons to reject the proposed rule change to list the COIN ETF:
Bitcoin's protocol is unfinished under conflicting development.
There is evidence that markets have been manipulated by the exchanges for years, China being the most notorious example until PBOC intervention. The biggest and most influential Bitcoin exchange 'Bitfinex' is located in Hong Kong and incorporated in the Virgin Islands, out of US jurisridction to keep an orderly market.
Mining activity which is the most important component of the Bitcoin network is almost centralized in China where the USA authorities can't reach to protect the miners and consequently protect the ETF investors. If averagely decentralized no protection would be needed.
The production of mining equipment is 100% centralized in China.
Original bitcoin source code contained unfinished online Poker game code from its original creator Satoshi Nakamoto. Look into versions from 0.1.0 to 0.1.4, maybe later ones.
Bitcoin is artifically restricted by 'Core' devlopers at 1MB blocks of transactions and is already operating highly and dangerously over maximum capacity.
Reasons to NOT reject the proposed rule change:
Accidentally or not, Bitcoin is a genius potentially world changing project.
Its units of ownership named 'bitcoin' with the undercase 'b' have the price backed by its utility like any other commodity and as historical usage graphics can show the utility tends to grow very fast but it is being restricted by the widely known and contentious scaling debate.
The ETF provides a safe trading environment to American investors and traders.
The ETF should be approved only after all those problems are solved or alleviated, currently investors would be under very high risk and the ETF should not be approved. Bitcoin itself is under high risk.