March 27, 2019
From: info [redacted] Sent: Wednesday, March 27, 2019 9:08 PM To: TradingAndMarkets; TMOIGLOG Subject: presentation given by Bitwise to SEC - comments Dear Madam or Sir, Please forward my comments to - Lauren Yates, Office of Market Supervision. I did read the article on a news site which pointed to a report of a presentation given by Bitwise to SEC - https://www.sec.gov/comments/sr-nysearca-2019-01/srnysearca201901-5164833-183434.pdf We, at arstech.biz collect and analyze non-stop and in real time information directly from around 36 cryptoexchanges. I dispute and disagree with most of the statements and findings in the Bitwise presentation. 1. Regarding - “…the true spot market for bitcoin essentially exists on 10 different exchanges conducting nearly $300 million in daily trading volume.” Most of the ‘action’ (2/3rd or more) in cryptocurrencies trading is done outside of US, mainly in Asia. Most of the 10 exchanges on the list are US based and reflect only fraction of the total trades. 2. Regarding the technical side - pg41“…So we built infrastructure to programmatically read data off the screen. We read the order book and recent trades four times a second.”. Browser windows can offer only a fraction of the trades - it is for illustration and not for research. The window is not updated in real time and for sure takes longer than 1/4s. Some exchanges provide REST API access to their order books. All exchanges provide REST API access to ticker - bid/ask price & volume. An API call to get ticker pricing or order books takes anywhere from half a second to several seconds to complete. 3. Regarding - "pg83...The bitcoin market and Bitwise’s specific proposal are uniquely resistant to manipulation, and the regulated and surveilled futures market is significant" In a global crypto market if coin pricing on the 'alleged fake volume' exchanges move, the coin pricing on the 'alleged good volume' 10 exchanges has either to follow or experience losses. Bitwise has no idea what market manipulation in cryptocurrency looks like. If SEC is interested I can show in chart images that we did generate what looks like an event of manipulation. Best Regards, Paul Arssov.