Nov. 29, 2023
Q1a: What are commenters’ views on whether the proposed Fund and Shares would be susceptible to manipulation? A1a: Under responsibility of Fund Managers, the risks are no greater, perhaps less, under corporate governances similar to those used for securities. Q1b: What are commenters’ views generally on whether the Exchange’s proposal is designed to prevent fraudulent and manipulative acts and practices? A1b: Preventing fraud, under any circumstances is not an activity that can be regulated. There will always be people/entities who ignore laws to seek advantages for their own gains. USG and Private Institutions should work together to remove bad actors. Q1c: What are commenters’ views generally with respect to the liquidity and transparency of the bitcoin markets and the bitcoin markets’ susceptibility to manipulation? A1c: After the initial transition, Spot ETFs will significantly reduce likely occurrence of manipulations and improve transparency. Bitcoin inherently offers transparency and with the base inflows from large institutions Bitcoin will level to a stable level driven by supply and demand very similar to equities/commodities. Q2: Overall A2: In the context of manipulations, I believe the Spot Bitcoin will be significantly larger and less likely to dramatic changes relative to the Futures movements. Specifically, the Spot Bitcoin will see investors Holding rather than reacting to same degree of fluctuations with Futures. Again, in my opinion, Spot or even Futures manipulation are less likely due to the Use Case; store value Q3. Overall A3: I am familiar with technology, and believe the decentralized architecture and creation of Bitcoin will present unprecedented challenges for manipulations. Again, there will be those who seek advantage for themselves however, the collective crypto environment should allow for more rapid closure through forensic sciences than with fiat or commodities. Q4. Overall A4. In my opinion, Coinbase has dramatically improved its own governance as well as reacted to changes.requests from the SEC and others. Adding Coinbase with institutional partners would likely fortify or harden against any nefarious actors who intend to manipulate or attempt to incur actions against investors. Q5: Overall A5: To the extent there will be some correlations, it is likely to be no different than spot/futures for other commodities. Of course, this will apply once the initial settling of inflows to Spot ETFs that will occur as new long term investors establish their positions.