July 27, 2018
To the Staff of the Securities and Exchange Commission:
Bitcoin ETFs come into direct conflict with the Commission's stated priorities to protect retail investors. Presumably, ETF products make it easier for brokers and investment advisers to offer Bitcoin to their clients. Given the ability for individuals to access bitcoin markets through a number of Cryptocurrency exchanges, the clear purpose for a bitcoin ETF is to open up the market to a less knowledgeable and less informed base of individuals.
Additionally, a Bitcoin ETF presents serious market infrastructure concerns. If the inherent nature of Bitcoin makes it vulnerable to hacking (not the cryptography of the blockchain itself but its storage), there are serious custody issues to be concerned with that, with the growth and expansion of the Bitcoin market, could create counter-party and extensive market risks in the event of a hack. Additionally, given some of the other issues with ETFs as of late (VIX products, leveraged ETFs) it seems odd that there is even a willingness to push the envelope even further out on the risk spectrum.
Finally, the Commission is considering aiding a financial product that has historically been associated with money laundering, crime, and cyber-security issues when, at the same time, has stated that these are all priorities and a focus for the Staff. Curtailing ETFs does not stifle the growth of technology, it inhibits speculation and protects those individuals that SEC has a mandate to protect.
Thank you for continuing to seek broad based input and fulfilling your goals of maintaining fair and stable markets that protect all investors.