February 15, 2019
Compared to either the Winklevoss filing or the Van Eck filing, this new filing is clearly better in several regards.
First, there is none of this silly "we will self-custody the coins" nonsense. That is a truly terrible idea and if Bitwise will use a regulated 3rd party custodian to hold the coins that is a HUGE step forward.
Second, the use of a lot of bitcoin exchanges, "approximately 10" that account for "a majority of the total global volume of bitcoin traded on exchanges" is obviously is superior to the Winklevoss proposal to use just one small related exchange that is maybe 1% of global bitcoin trading. Since the US bitcoin futures also use a tiny number of exchanges, as few as one, this seems far better compared to that approach as well.
The pricing approach is also better than the Van Eck proposal to use prices from a few OTC desks (the inevitable scandal down the road from THAT approach already has a ready made nickname name. Take the "Libor scandal", change it a bit, and you have the "Bibor scandal"). The SEC may have to live with OTC pricing with fixed income and gold trading, because there is no other good alternative, but there is zero reason to use OTC pricing here.
Of course a key here for the SEC should be what sort of data Bitwise shows up with to support their filing. We all look forward to seeing it.