Jul. 23, 2021
In my comments, I will first refer back to past objections the SEC has made when considering Bitcoin ETF applications; “...demonstrating that there is a comprehensive surveillance-sharing agreement with a regulated market of significant size relating to the underlying assets. “ I find it more then a little puzzling the regulatory body with the sole authority to establish and enforce rules for crypto exchanges that would provide investor protections is the same body that has repeatedly stated they will not approve a Bitcoin ETF because these exchanges are not sufficiently regulated to protect against manipulation . If you do not believe you have this authority for a new asset class you have merely to ask congress for it. The fact is, congress has on multiple occasions ask you if you need more authority, with Senator Elizabeth Warren being the latest demanding you respond and explain what you need and why you have not yet asked for it. Worse yet, this shouldn’t be complex or difficult set of rules to implement. You have merely to state that the same rules and data compliance mechanisms used in tradition exchanges should also be applied to crypto exchanges. There is no need to reinvent the wheel to provide investors with the protection you responsible for providing. Given the above, I find the SEC remiss of his critical responsibilities to not yet have instituted these crypto exchange rules and quite possibly. One does begin to wonder this is an intentional lack of action in order to slow the growth of a new asset class that very clearly threatens the existing traditional equities, finance and currency systems. In summary, it appears the only thing that is keeping the SEC from approving the many qualified Bitcoin ETF applications is the SEC’s own lack of action. You are solely responsible for regulation of these markets, and if you do not believe you have this authority members in congress have directly asked (on multiple occasions) that you state this and they will provide it to you. Btw, the advantages that this new class of assets and related exchanges are built around, namely blockchain, provides a unique and novel means for exchanges to record the trading activity in question and provide it to either you and the public in an entirely transparent and verifiable fashion. This can be done much the same way Bitcoin itself operates, in a quasi anonymous fashion and then easily connected back to the KYC systems exchanges already maintain when you so determine an investigation or audit is required. Best Regards Douglas Slemmer