Dec. 6, 2023
Thank you for this public comment window for thoughts, ideas, and issues the SEC (and other regulators) should consider en route to approving a Spot Bitcoin EFT investment product for investors. I have brokerage and retirement account relationships with the popular exchanges that hold my Bitcoin, Ethereum, Cardano, Solana, Litecoin, Chainlink, Dogecoin, Matic, among other digital assets. I am a long-time investor and long-term stakeholder in the digital asset community and feel both qualified and grateful for this opportunity to voice my opinion, comments, and concerns when the spot Bitcoin ETF investment product is approved for investors. I am also a Certified Anti-Money Laundering Specialist, Certified Fraud Examiner, maintain CAMS-FCI and CAMS-Audit certifications, a Certified Regulatory Compliance Manager, and a candidate for the Certified Crypto asset Anti-Financial Crime Specialist (CCAS) Certification. I have spent decades in risk management, compliance, internal audit, and fraud analysis to comment on the crypto industry and marketplace. YES to a Spot Bitcoin ETF investment product approval; Yes to a Spot Ethereum ETF investment product approval; Yes to a Spot Cardano ETF investment product approval; Yes to a basket or bundling of digital asset ETF investment product approval that includes a medley or combination of digital assets! Yes to approving any legitimate digital asset ETF investment product that meets a certain market cap threshold and other SEC criteria as a legitimate digital asset ETF investment product for retail and institutional investors. NO to Coinbase for having an apparent monopoly on providing third party custody services for any and all Spot ETF product applications now or in the future which could open the door to anti-trust and anti-competitive issues. I still strongly agree with the critics of digital assets that cryptocurrency is by itself not a security and these assets are still prone to and vulnerable to fraud, money laundering, financial crimes, and other illicit activity. So is cash and currency. When I established my accounts and relationships with the exchanges named above there was no apparent KYC (Know Your Customer) procedures and disclosures, no disclosures issued at all, and other regulatory compliance procedures during my onboarding and funding of accounts. Given the magnitude of the cryptocurrency market combined with the heightened anticipation for the Spot ETF approval date – all expert eyes and media attention seems to have pinned January 8, 9, or 10, 2024, as the date of likely approval – a date more anticipated by investors like me than New Year's Day in the crypto market. I would strongly recommend the SEC approve any cryptocurrency Spot ETF with the firm caveat (and interagency guidance) that the widely used cryptocurrency exchanges first and foremost, be forced to implement and maintain the same risk management, Bank Secrecy Act, anti-money laundering, OFAC, and fraud risk management policies, procedures, and internal controls, as the traditional asset and money managers must maintain with the requisite regulatory scrutiny and oversight. I want my assets and the tsunami of new investor assets that will flood this market protected with governance, risk mitigation, compliant with BSA and AML regulations and internal controls. I am without a doubt one of hundreds if not thousands of responders and comments to this open comment window, and quite certain that other comments with more hands-on experience than me, have similar and even more concerns than me. Optimally, and for the benefit of all investors and stakeholders, I would like to see the following timeline and events in 2024 as follows: January 8, 9, or 10, 2024 as the green light date by the SEC announcing that Spot Bitcoin ETFs are approved. Approval of applications for spot Bitcoin and Ethereum ETF products will auger applications for other altcoins and less popular digital assets. March 12, 2024, as the earliest date the ETF investment product can be launched. Starting on this date Venus (planet of stored value is energized and exalted in Pisces, and Pluto is out of Capricorn and firmly transiting through Aquarius full time). March 31, 2025, cryptocurrency exchanges must implement adequate governance, risk management, and BSA and AML compliance policies, procedures, and controls, via Interagency guidance and final rules. This will create more risk management, compliance, and internal audit roles and opportunities in the digital asset market in the future. Thank You! HAD