July 11, 2018
Dear Sirs,
Listing of a Bitcoin ETF is premature, even if it is addressed solely to professional investors. The issue is that price discovery for bitcoin is potentially heavily distorted, regardless of how many bitcoin exchanges are used as a price index basis..
It has been widely assumed by people active in the crypto space and can anecdotally be seen each time an organization called tether conceives new US Dollars out of thin air that bitcoin price reacts strongly to this.
A university paper has recently found statistical evidence: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3195066
The amount of scams and the anecdotal evidence of spoofing, wash trading and insider dealing in the crypto markets, including bitcoin, is at an unsustainable level. I strongly suggest you do not make this an asset class before price discovery functions normally.
The very least that should be done before a bitcoin ETF is allowed is to investigate the organization called tether that has printed 2.8 billion US Dollars without providing even one audit, claiming their USDT token are backed one to one with real US Dollars and redeemable. If a bitcoin eTF is launched before this issue, which I believe to be a major one, is solved, I believe it sends the wrong signal to markets.
Sincerely,