Subject: File No. SR-NYSEArca-2021-90
From: Daniel
Affiliation:

Mar. 19, 2022

 

The following 4 exchanges are used in in calculating the Bitcoin Reference Rate on which CME bitcoin futures are based: Bitstamp, Coinbase, Itbit and Kraken. There are ETFs based on these CME bitcoin futures. 



GBTC uses the CoinDesk Bitcoin Price Index which is based on these four exchanges: Bitstamp, Coinbase, itBit, OKCoin. Looking at section 8.3 of this link 

https://www.cmegroup.com/education/articles-and-reports/analysis-of-cme-cf-bitcoin-reference-rate.html 

we can see a flash crash on the CoinDesk Bitcoin Price Index. I think the problem is the inclusion of the OKCoin exchange. If GBTC were to use Kraken instead of OKCoin then it would be using the same 4 exchanges to calculate a bitcoin reference index and the SEC should allow a GBTC to convert to a spot bitcoin ETF. 




Daniel