May 6, 2025
Dear Securities and Exchange Commission, I am writing to support the CanaryFunds Litecoin ETF proposal, addressing the Commission’s concerns about preventing fraudulent and manipulative practices and evaluating any new or novel issues. The CanaryFunds Litecoin ETF offers a regulated investment vehicle for Litecoin (LTC), a transparent, decentralized cryptocurrency with over a decade of 100% uptime. Below, I outline why this proposal aligns with the SEC’s investor protection objectives. Preventing Fraudulent and Manipulative Practices The ETF incorporates several robust safeguards: Secure Custody: Cold storage for Litecoin assets, managed by a reputable custodian, mirrors standards in approved Bitcoin and Ethereum ETFs, minimizing hacking risks. Transparent Pricing: The ETF tracks the CoinDesk Litecoin Price Index (LTX), aggregating data from multiple reputable platforms to ensure accurate, manipulation-resistant pricing. Market Surveillance: Litecoin’s top-25 market capitalization and CFTC-regulated futures market support liquidity and effective oversight, akin to Bitcoin ETF frameworks. Compliance: Adherence to AML/KYC regulations and regular holdings disclosures ensures transparency. No New or Novel Concerns The proposal raises no issues beyond those addressed in Bitcoin and Ethereum ETF approvals. Litecoin, a proof-of-work cryptocurrency forked from Bitcoin’s codebase, is widely regarded as a commodity, not a security, as noted by Bloomberg ETF analyst James Seyffart. Its resilience against 51% attacks and mining pool concentration, a common trait in proof-of-work networks, poses no unique risks. The ETF’s design further insulates investors from blockchain-specific concerns. Investor and Market Benefits Approving the ETF would provide a regulated, cost-effective way for investors to access Litecoin, aligning with the $60 billion Bitcoin ETF market. It would also reinforce U.S. leadership in regulated crypto markets under Mark Uyeda’s favorable regulatory environment. Conclusion The CanaryFunds Litecoin ETF is designed to prevent fraud and manipulation through secure custody, transparent pricing, and robust surveillance, raising no novel concerns. I urge the Commission to approve this proposal, enabling safe investor participation in the growing cryptocurrency market. Thank you for considering this comment. Sincerely, Christian Sullivan [REDACTED]