July 5, 2019
Dear All, I would like to keep this simple and say why it is inappropriate for any ETP to go ahead at this moment in time. There have been many arguments been put forward for why an ETP is a necessity right now. The most salient amongst these is that it will foster innovation and bring liquidity into the marketplace. On both counts, I would have to say these are wrong reasons to grant an ETP based on Bitcoin. Argument 1- Innovation: Bitcoin and Blockchain fall under the category of "Financial Technology" aka "FinTech" and a 'Bitcoin ETP' does not fall under this category: more comparable to the securitisation of an Asset, e.g. the Mortgage Backed Security (MBS). It is a financial product and granting it does not in any way guarantee that the USA will win the technological innovation race in any way! There is no real race to begin with, as Bitcoin and Blockchain are a just a small section of FinTech among other areas of innovation such as Big Data, Artificial Intelligence, Deep and Thin Learning, Robo Advising, Insurtech, Payments Systems (e.g. mobile phone, e-wallets), Lending Platforms and numerous other areas. And the USA is doing fine in leading the way in the majority of these sections. Bitcoin and Blockchain are just a small part of the bigger picture and building an ETP on an unregulated sector no matter how convincing the arguments the people who are selling these products provide us without some regulatory guidance, even a Regulatory Sandbox Approach for companies who wish to innovate in this area, I say no to this idea. (For those that are not familiar with a Regulatory Sandbox Approach see the UK FCA link: https://www.fca.org.uk/publication/research/regulatory-sandbox.pdf). This article on Global approaches to Regulatory Sandbox by Delloite may be of interest: https://www2.deloitte.com/cn/en/pages/risk/articles/thinking-out-of-the-regulatory-sand-box.html I realise Cryptocurrencies such and Bitcoin and Blockchains as FinTech are treading new ground and are proving hard for regulators to strike a balance between providing just the right amount of regulatory guidance without stifling innovation. However, too fast a pace of innovation and without regulatory oversight in technological innovation has many risks and we have already seen an increase in cybercrime and spending on illicit activities using Bitcoin- we are set to spend $1Billion this year on drugs on darknet marketplaces according to Bloomberg (https://blockonomi.com/1b-industry-bitcoin-dark-web-markets/amp/). Creating a financial product on top of this young asset class can be considered irresponsible at this stage. Argument 2- Liquidity: For the reasons set out above: lack of even the most basic regulation or guidance in just what is one part of the US FinTech area, one fraught with issues such as cybercrime and money funnelling into the underground market for drugs, illegal pornography and terrorism is it really a good idea to inject liquidity into an asset that is widely recognised as an emerging systemic risk? As you can see the whole reason for granting a Bitcoin ETP is genuinely very opaque and the SEC should deny this request presently. Regards, Scott