March 8, 2017
I am in favor of the proposed rule.
Many commenters voiced concerns about systemic and political risks of bitcoin. If I understand correctly, the SEC's role here is not to micromanage the risks of the commodity pool. Even if we were to assume so, the systemic and political risks of bitcoin and the blockchain are no different from those in other commodities. If we were to see another OPEC-style oil shock, I highly doubt the SEC would prevent the listing and trading of an oil trust fund. This is the same political risk we would see if the PBOC was indeed manipulating the price of bitcoin.
The SEC has more than enough disclosure requirements to protect investors from fraud and manipulative practices. The information circular requirements listed in the notice of proposed rule change appear to provide a sufficient prospectus for potential investors.
Also, I believe listing and trading this trust will remove many of the impediments to buying bitcoins. Currently, many bitcoin transactions occur in person through risky peer-to-peer transactions done in person and online. For example, see https://localbitcoins.com/
There are no intermediaries to facilitate the exchange of dollars for bitcoins by holding each in escrow. Listing this trust is in the public interest because it will give investors a safer alternative and give greater liquidity to the bitcoin market.
Harold Primm III
Student, Boston University School of Law