Self-Regulatory Organizations; Bats BZX Exchange, Inc.; Order Instituting Proceedings To Determine Whether To Approve or Disapprove a Proposed Rule Change to BZX Rule 14.11(e)(4), Commodity-Based Trust Shares, To List and Trade Winklevoss Bitcoin Shares Issued by the Winklevoss Bitcoin Trust, 71778-71782 [2016-25082]
Download as PDF
71778
Federal Register / Vol. 81, No. 201 / Tuesday, October 18, 2016 / Notices
Dated: October 11, 2016.
Robert W. Errett,
Deputy Secretary.
[FR Doc. 2016–25088 Filed 10–17–16; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
Proposed Collection; Comment
Request
Upon Written Request, Copies Available
From: Securities and Exchange
Commission, Office of FOIA Services,
100 F Street NE., Washington, DC
20549–2736.
Lhorne on DSK30JT082PROD with NOTICES
Extension:
Rule 6a–4, Form 1–N; SEC File No. 270–
496, OMB Control No. 3235–0554.
Notice is hereby given that pursuant
to the Paperwork Reduction Act of 1995
(44 U.S.C. 3501 et seq.), the Securities
and Exchange Commission
(‘‘Commission’’) is soliciting comments
on the collection of information
provided for in Rule 6a–4 and Form 1–
N, summarized below. The Commission
plans to submit this existing collection
of information to the Office of
Management and Budget for extension
and approval. The Code of Federal
Regulation citation to this collection of
information is 17 CFR 240.6a–4 and 17
CFR 249.10 under the Securities
Exchange Act of 1934 (15 U.S.C. 78a et
seq.) (the ‘‘Act’’).
Section 6 of the Act 1 sets out a
framework for the registration and
regulation of national securities
exchanges. Under the Commodity
Futures Modernization Act of 2000, a
futures market may trade security
futures products by registering as a
national securities exchange. Rule 6a–
4 2 sets forth these registration
procedures and directs futures markets
to submit a notice registration on Form
1–N.3 Form 1–N calls for information
regarding how the futures market
operates, its rules and procedures,
corporate governance, its criteria for
membership, its subsidiaries and
affiliates, and the security futures
products it intends to trade. Rule 6a–4
also requires entities that have
submitted an initial Form 1–N to file: (1)
Amendments to Form 1–N in the event
of material changes to the information
provided in the initial Form 1–N; (2)
periodic updates of certain information
provided in the initial Form 1–N; (3)
certain information that is provided to
the futures market’s members; and (4) a
1 15
U.S.C. 78f.
CFR 240.6a–4.
3 17 CFR 249.10.
2 17
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13:19 Oct 17, 2016
Jkt 241001
monthly report summarizing the futures
market’s trading of security futures
products. The information required to
be filed with the Commission pursuant
to Rule 6a–4 is designed to enable the
Commission to carry out its statutorily
mandated oversight functions and to
ensure that registered and exempt
exchanges continue to be in compliance
with the Act.
The respondents to the collection of
information are futures markets.
The Commission estimates that the
total annual burden for all respondents
to provide ad hoc amendments 4 to keep
the Form 1–N accurate and up to date
as required under Rule 6a–4 would be
60 hours (15 hours/respondent per year
× 4 respondents 5) and $400 of
miscellaneous clerical expenses. The
Commission estimates that the total
annual burden for all respondents to
provide annual and three-year
amendments 6 under Rule 6a–4 would
be 88 hours (22 hours/respondent per
year × 4 respondents) and $576 ($144
per year × 4 respondents 7). The
Commission estimates that the total
annual burden for the filing of the
supplemental information 8 and the
monthly reports required under Rule
6a–4 would be 24 hours (6 hours/
respondent per year × 4 respondents 9)
and $240 of miscellaneous clerical
expenses. Thus, the Commission
estimates the total annual burden for
complying with Rule 6a–4 is 172 hours
and $1216 in miscellaneous clerical
expenses.
Compliance with Rule 6a–4 is
mandatory. Information received in
response to Rule 6a–4 shall not be kept
confidential; the information collected
is public information.
Written comments are invited on: (a)
Whether the proposed collection of
information is necessary for the proper
performance of the functions of the
agency, including whether the
information shall have practical utility;
(b) the accuracy of the agency’s estimate
of the burden of the proposed collection
of information; (c) ways to enhance the
quality, utility, and clarity of the
information to be collected; and (d)
ways to minimize the burden of the
collection of information on
respondents, including through the use
of automated collection techniques or
4 17
CFR 240.6a–4(b)(1).
Commission estimates that four exchanges
will file amendments with the Commission in order
to keep their Form 1–N current.
6 17 CFR 240.6a–4(b)(3) and (4).
7 The Commission notes that while there are
currently five Security Futures Product Exchanges,
one of those exchanges, NQLX, is dormant.
8 17 CFR 240.6a–4(c).
9 See supra footnote 7.
5 The
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other forms of information technology.
Consideration will be given to
comments and suggestions submitted in
writing within 60 days of this
publication.
An agency may not conduct or
sponsor, and a person is not required to
respond to, a collection of information
under the PRA unless it displays a
currently valid OMB control number.
Please direct your written comments
to: Pamela Dyson, Director/Chief
Information Officer, Securities and
Exchange Commission, c/o Remi PavlikSimon, 100 F Street NE., Washington,
DC 20549 or send an email to: PRA_
Mailbox@sec.gov.
Dated: October 12, 2016.
Robert W. Errett,
Deputy Secretary.
[FR Doc. 2016–25089 Filed 10–17–16; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–79084; File No. SR–
BatsBZX–2016–30]
Self-Regulatory Organizations; Bats
BZX Exchange, Inc.; Order Instituting
Proceedings To Determine Whether To
Approve or Disapprove a Proposed
Rule Change to BZX Rule 14.11(e)(4),
Commodity-Based Trust Shares, To
List and Trade Winklevoss Bitcoin
Shares Issued by the Winklevoss
Bitcoin Trust
October 12, 2016.
On June 30, 2016, Bats BZX Exchange,
Inc. (‘‘BZX’’ or ‘‘Exchange’’) filed with
the Securities and Exchange
Commission (‘‘Commission’’), pursuant
to Section 19(b)(1) of the Securities
Exchange Act of 1934 (‘‘Act’’) 1 and Rule
19b–4 thereunder,2 a proposed rule
change to list and trade Winklevoss
Bitcoin Shares (‘‘Shares’’) issued by the
Winklevoss Bitcoin Trust (‘‘Trust’’)
under BZX Rule 14.11(e)(4). The
proposed rule change was published for
comment in the Federal Register on July
14, 2016.3
The Commission has received six
comment letters on the proposed rule
change.4 On August 23, 2016, pursuant
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Securities Exchange Act Release No. 78262
(Jul. 8, 2016), 81 FR 45554 (‘‘Notice’’).
4 See Letters from Robert D. Miller, VP Technical
Services, RKL eSolutions (July 11, 2016) (‘‘Miller
Letter’’); Jorge Stolfi, Full Professor, Institute of
Computing UNICAMP (July 13, 2016) (‘‘Stolfi
Letter’’); Guillaume Lethuillier (July 26, 2016)
(‘‘Lethuillier Letter’’); Michael B. Casey (July 31,
2016) (‘‘Casey Letter’’); Erik A. Aronesty, Sr.
Software Engineer, Bloomberg LP (Aug. 2, 2016)
2 17
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Federal Register / Vol. 81, No. 201 / Tuesday, October 18, 2016 / Notices
to Section 19(b)(2) of the Act,5 the
Commission designated a longer period
within which to approve the proposed
rule change, disapprove the proposed
rule change, or institute proceedings to
determine whether to disapprove the
proposed rule change.6 This order
institutes proceedings under Section
19(b)(2)(B) of the Act 7 to determine
whether to approve or disapprove the
proposed rule change.
Lhorne on DSK30JT082PROD with NOTICES
I. Summary of the Proposal 8
The Exchange proposes to list and
trade the Shares under BZX Rule
14.11(e)(4), which governs the listing
and trading of Commodity-Based Trust
Shares on the Exchange.9 The Shares,
which will be registered with the
Commission by means of the Trust’s
Registration Statement,10 represent
units of fractional undivided beneficial
interest in and ownership of the Trust.
Digital Asset Services, LLC will be the
sponsor of the Trust (‘‘Sponsor’’).
Gemini Trust Company, LLC, the
custodian of the Trust (‘‘Custodian’’),
(‘‘Aronesty Letter’’); and Dan Anderson (Aug. 27,
2016) (‘‘Anderson Letter’’). All comments on the
proposed rule change are available on the
Commission’s Web site at: https://www.sec.gov/
comments/sr-batsbzx-2016-30/
batsbzx201630.shtml.
5 15 U.S.C. 78s(b)(2).
6 See Securities Exchange Act Release No. 78653,
81 FR 59256 (Aug. 29, 2016). The Commission
designated October 12, 2016, as the date by which
it should approve, disapprove, or institute
proceedings to determine whether to disapprove the
proposed rule change.
7 15 U.S.C. 78s(b)(2)(B).
8 The Commission notes that additional
information regarding the Trust and the Shares,
including investment objectives, risks, creation and
redemption procedures, fees, portfolio holdings
disclosure policies, calculation of NAV,
distributions, and taxes, as well as additional
background information about bitcoins and the
Bitcoin network, including information relating to
Bitcoin network operations, bitcoin transfers and
transactions, cryptographic security used in the
Bitcoin network, Bitcoin mining and creation of
new bitcoins, the mathematically controlled supply
of bitcoins, modifications to the Bitcoin protocol,
among other things, can be found in the Notice (see
supra note 3) and the registration statement filed
with the Commission on Form S–1 (File No. 333–
189752) under the Securities Act of 1933
(‘‘Registration Statement’’), as applicable.
9 See BZX Rule 14.11(e)(4)(C) (permitting the
listing and trading of ‘‘Commodity-Based Trust
Shares,’’ defined as a security (a) that is issued by
a trust that holds a specified commodity deposited
with the trust; (b) that is issued by such Trust in
a specified aggregate minimum number in return for
a deposit of a quantity of the underlying
commodity; and (c) that, when aggregated in the
same specified minimum number, may be
redeemed at a holder’s request by such Trust which
will deliver to the redeeming holder the quantity of
the underlying commodity).
10 See Registration Statement, supra note 8. The
Exchange states that the most recent amendment to
the Registration Statement was filed on June 29,
2016, and that the Registration Statement will be
effective as of the date of any offer and sale
pursuant to the Registration Statement.
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13:19 Oct 17, 2016
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will hold the deposited bitcoins on
behalf of the Trust in a segregated
custody account. The Exchange has
represented that the Custodian will use
its proprietary and patent-pending
offline (i.e., air-gapped) cold-storage
system to store the Trust’s bitcoins.11
According to the Exchange, the Trust
will hold only bitcoins as an asset.12
The investment objective of the Trust is
for the Shares to track the price of
bitcoins, as measured by the spot price
at 4:00 p.m. Eastern time on the Gemini
Exchange 13 each day the Exchange is
open for trading, minus the Trust’s
liabilities (which include accrued but
unpaid fees and expenses). On each
business day, the Trust’s administrator
will use the Gemini Exchange spot price
as measured at 4:00 p.m. Eastern time to
calculate the Trust’s net asset value
(‘‘NAV’’). The Trust will issue and
redeem the Shares in ‘‘Baskets’’ only to
certain Authorized Participants on an
ongoing basis.14 Creation Baskets will
be distributed to the Authorized
Participants by the Trust in exchange for
the delivery to the Trust of the
appropriate number of bitcoins (i.e.,
bitcoins equal in value to the value of
the Shares being purchased). On a
redemption, the Trust will distribute
bitcoins equal in value to the value of
the Shares being redeemed to the
redeeming Authorized Participant in
exchange for the delivery to the Trust of
one or more Baskets. On each business
day, the value of a Basket for a creation
transaction and the value of a Basket for
a redemption transaction will be equal
to one another (i.e., each Basket will
consist of 50,000 Shares, and the value
11 According
to the Exchange, the Custodian is an
affiliate of the Sponsor and a New York Statechartered limited liability trust company that
operates under the direct supervision and
regulatory authority of the New York State
Department of Financial Services. The Trust’s
public Bitcoin addresses are established by the
Custodian using its proprietary hardware and
software security technology. The Trust will
employ security procedures, described in greater
detail in the Notice and the Registration Statement,
to safeguard the bitcoin assets of the Trust. See
Notice and Registation Statement, supra notes 3 and
8, respectively.
12 As described in greater detail in the Notice and
the Registration Statement, a bitcoin (with a lower
case ‘‘b’’) is a digital asset that is based on the
decentralized, open-source protocol of the peer-topeer Bitcoin computer network. The Bitcoin
network (with a capital ‘‘B’’) hosts the decentralized
public transaction ledger, known as the
‘‘Blockchain,’’ on which all bitcoins are recorded.
See Notice and Registation Statement, supra notes
3 and 8, respectively.
13 The Gemini Exchange is a digital-asset
exchange owned and operated by the Custodian and
is an affiliate of the Sponsor.
14 Each Basket will consist of 50,000 Shares, and
the value of the Basket will be equal to the value
of 50,000 Shares at their NAV per Share on that
day.
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Fmt 4703
Sfmt 4703
71779
of the Basket will be equal to the value
of 50,000 Shares at the NAV per Share
on that day).
II. Summary of Comment Letters
The Commission has received six
comment letters on the proposed rule
change.15 The following is a summary of
those letters.
A. Timing of the Proposal and Investor
Access to Bitcoin
One commenter states that the
proposal is a timely opportunity for the
Exchange and investors, and that the
proposal will allow investors to invest
in the technology without having to deal
with the complexity of holding bitcoins
directly.16 Another commenter states
that it supports the goals of the Trust
and finds the proposal to be appropriate
and timely, noting that Bitcoin is in a
pivotal year and is maturing, and noting
that the average number of daily Bitcoin
transactions is currently 200,000, that
more than 350,000 unique addresses are
being used to hold bitcoins,17 and that
the Bitcoin miners (who validate
transaction blocks through
computational hashes) conduct more
than a billion hashes per second.18 In
addition, the commenter states that, in
practice, while using Bitcoin may
appear complex and forbidding, based
on fear of theft and concerns about legal
and tax issues, among other things, the
Trust can help a whole category of
people to gain access, albeit indirectly,
to Bitcoin.19
B. Need for Additional Control and
Security Measures
With respect to security measures to
be implemented by the Trust, one
commenter recommends that additional
steps mandating ‘‘proof of control’’
audits be employed to protect the
consumers of this ETP.20 Specifically,
the commenter recommends a monthly
‘‘proof of control’’ audit of all of the
Trust’s bitcoins to be performed by the
Custodian and provided to the Sponsor,
who should display the signed messages
on its Web site to publicly demonstrate
proof of control over the bitcoins held
by the Trust.21 According to this
commenter, the message to be signed
can be the mined hash of a
15 See
supra note 4 and accompanying text.
Miller Letter, supra note 4.
17 Additional information about Bitcoin addresses
and storage, mining, bitcoin transfers, and the
Blockchain, among other things, can be found in the
Notice. See Notice, 81 FR at 45556–45561, supra
note 3.
18 See Lethuillier Letter at 1–2, supra note 4.
19 See id. at 2.
20 See Casey Letter, supra note 4.
21 See id. at 2.
16 See
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Federal Register / Vol. 81, No. 201 / Tuesday, October 18, 2016 / Notices
predetermined block height, which is
guaranteed to be both easily verifiable
and unknown in advance,22 and the
signatures can be created with the
private keys still in cold storage and airgapped.23 This commenter notes that
publicly identifying the addresses
holding the bitcoins adds no risk to
them being stolen due to the nature of
Bitcoin.24 According to the commenter,
the bitcoins remain secure from even
quantum attack as the public key is
never revealed, no additional risk is
incurred by publishing the proof-ofcontrol audit, and opening control to
public audit vastly increases confidence
in possession and control of the
underlying asset.25 In addition, the
commenter notes that publishing the
proof-of-control audit on a monthly
basis would not place an undue burden
on either the Sponsor or Custodian, as
less-regular audits are scheduled in any
event.26
Another commenter addressed proofof-control audits, adding that, unlike
with non-digital assets, an ‘‘audit’’ of
assets in bitcoins can be low cost,
public, and automated, and that there is
no legitimate reason to maintain secrecy
of the holdings involved in a trust or
exchange.27 This commenter notes that
a well-managed trust should be able to
trivially update its proof of assets at
least once every day, if not more often
(every time a bitcoin is moved or
acquired).28 This commenter proposes
that the Commission require that any
trust holding bitcoins either (i) maintain
insurance on its assets, or (ii) allow for
public, daily audit of funds. Without
one of those two measures, the
commenter states, investors in a bitcoin
trust cannot be reasonably assured that
their investment is being soundly
custodied.29 The commenter concludes
by stating that, given the nature of
bitcoins as electronic assets, a public
and daily proof, rather than the stated
provisions for private audits, should
also be considered.30
Another commenter states that,
according to the proposed rule change,
the Custodian’s Cold Storage System
utilizes multiple-signature (‘‘Multisig’’)
technology with an ‘‘M-of-N’’ signing
design that requires a signature from
more than one (1) Signer (but fewer than
the full complement of potential
Signers) in order to move the Trust’s
Lhorne on DSK30JT082PROD with NOTICES
22 See
id.
23 See id.
24 See id.
25 See id.
26 See id.
27 See Aronesty Letter, supra note 4.
28 See id.
29 See id.
30 See id.
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13:19 Oct 17, 2016
Jkt 241001
bitcoins.31 The commenter recommends
amending the proposal in order to
unambiguously specify the M-of-N
signing design used to secure the
Custodian’s Cold Storage System and to
require the Trust to notify interested
third parties, such as the Commission
or, as the case may be, the Trust’s
insurer, of any modification of the
Multisig characteristics in the future.32
Specifically, this commenter notes that
the proposed rule change fails to
provide a meaningful description of the
security level of the storage system
Multisig.33 The proposal, the
commenter asserts, ‘‘merely defines
what a [M]ultisig is, in general, while
only excluding the extreme cases M = 1,
insecure, and M = N, unpractical.’’ 34
The commenter states that the present
signing design is complicated by the fact
that the Signers, which are hardware
devices, are activated by Signatories,
which are human beings.35 The
commenter states that, as result, the
given definition is overly abstract and
incomplete. Because the signing design
is critical to the safety of the funds, the
commenter asserts, ‘‘the Trust should
communicate the following elements to
the interested third parties such as the
Commission or, as the case should be,
the Trust’s insurer: (i) Exact number of
required Signers; (ii) Exact number of
potential Signers; (iii) detailed
explanation of why the chosen M-of-N
configuration is adequate; (iv) complete
list of the Signatories and what Signer(s)
they can activate; and (v) useful
information related to the Signatories’
keys. . . . ’’ 36 The commenter adds
that the Trust should notify the relevant
persons without delay of any
modification of any of the above
elements: (i) Through (iii) should be
publicly announced, and, for security
reasons, (iv) and (v) should be notified
to the interested third parties only.37
C. Need for Insurance on the Fund’s
Holdings
A commenter notes that ‘‘[b]ecause
safety measures cannot prevent thefts
from the outside or the inside, [and]
because human rationality is inherently
bounded,’’ he does not support the fact
that the Trust’s bitcoins are not
insured.38 This commenter further
asserts that the Gemini Exchange was
31 Additional information about the ‘‘M-of-N’’
signing design can be found in the Notice. See
Notice, 81 FR at 45566–45567, supra note 3.
32 See Lethuillier Letter at 3, supra note 4.
33 See id.
34 See id.
35 See id.
36 See id.
37 See id.
38 See Lethuillier Letter at 2–3, supra note 4.
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Fmt 4703
Sfmt 4703
able to discover on its own a failure to
secure the secret keys that would
maintain the safe custody of bitcoins.39
D. Need for Regulation of the Bitcoin
ETP Industry
One commenter states that, despite
the advances in Bitcoin development,
owning and controlling bitcoins remains
a highly specialized task, which
includes secure management of private
keys and ‘‘fairly advanced technological
know-how.’’ 40 Because of the difficulty
and specialized knowledge required to
manage bitcoins, many investors rely on
exchanges to act as custodians of their
value. As a result, the commenter
believes that a Bitcoin ETP is a major
milestone and improvement and that it
is crucial that the Commission regulate
this industry.41 The commenter
concludes by noting that the concerns
regarding bitcoin security would be
greatly diminished were it possible to
trade an ETP backed by bitcoins, rather
than the bitcoins themselves.42
E. Speculative Nature of Bitcoin as an
Underlying Digital Asset
One commenter disagreed with the
notion that bitcoins are commodities;
rather, the commenter likened bitcoins
to be more like ‘‘penny stock’’ or shares
of a ponzi scheme.43 The commenter
notes that the market price of a bitcoin,
like that of a penny stock or ponzi fund,
is ‘‘entirely speculative, based on
expectations of traders about future
prices, which will be based on
expectations of future expectations.’’ 44
The commenter asserts that Bitcoin has
the essential characteristics of a penny
stock or a pyramid scheme: The profit
of early investors comes entirely from
the investment of later ones.45 In the
commenter’s view, because bitcoins are
primarily used for investment, bitcoins
should be regulated like a security, in
which case they should be regulated the
same way a penny stock or ponzi fund
would be.46 The commenter concludes
that the proposed ETF does not add any
productive mechanism to the
underlying bitcoins, but rather makes
bitcoins accessible to investments
funds, such as retirement funds.47
39 See
id.
Anderson Letter, supra note 4.
41 See id.
42 See id.
43 See Stolfi Letter, supra note 4.
44 See id.
45 See id.
46 See id.
47 See id.
40 See
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Federal Register / Vol. 81, No. 201 / Tuesday, October 18, 2016 / Notices
F. Concerns Regarding the Gemini
Exchange and the Gemini Exchange
Spot Price
One commenter expresses concerns
regarding the Gemini Exchange Spot
Price.48 Specifically, the commenter
states, the nominal price of the shares
under the proposal is supposed to be
tied to the market price of bitcoins at the
Gemini Exchange, which is closely tied
to the ETP proponents.49 In addition,
the commenter states, the Gemini
Exchange has relatively low liquidity
and trade volume in bitcoins.50 The
commenter asserts that there is a
significant risk that the nominal ETP
share price ‘‘will be manipulated, by
relatively small trades that manipulate
the bitcoin price at that exchange.’’ 51
III. Proceedings To Determine Whether
To Approve or Disapprove SR–
BatsBZX–2016–30 and Grounds for
Disapproval Under Consideration
The Commission is instituting
proceedings pursuant to Section
19(b)(2)(B) of the Act 52 to determine
whether the proposed rule change
should be approved or disapproved.
Institution of such proceedings is
appropriate at this time in view of the
legal and policy issues raised by the
proposed rule change. Institution of
proceedings does not indicate that the
Commission has reached any
conclusions with respect to any of the
issues involved. Rather, as described
below, the Commission seeks and
encourages interested persons to
provide comments on the proposed rule
change.
Pursuant to Section 19(b)(2)(B) of the
Act,53 the Commission is providing
notice of the grounds for disapproval
under consideration. The Commission is
instituting proceedings to allow for
additional analysis of the proposed rule
change’s consistency with Section
6(b)(5) of the Act, which requires,
among other things, that the rules of a
national securities exchange be
‘‘designed to prevent fraudulent and
manipulative acts and practices, to
promote just and equitable principles of
trade,’’ and ‘‘to protect investors and the
public interest.’’ 54
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IV. Procedure: Request for Written
Comments
The Commission requests that
interested persons provide written
48 See
id.
id.
50 See id.
51 See id.
52 15 U.S.C. 78s(b)(2)(B).
53 Id.
54 15 U.S.C. 78f(b)(5).
49 See
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13:19 Oct 17, 2016
Jkt 241001
submissions of their views, data, and
arguments with respect to the issues
identified above, as well as any other
concerns they may have with the
proposal. In particular, the Commission
invites the written views of interested
persons concerning whether the
proposal is consistent with Section
6(b)(5) or any other provision of the Act,
or the rules and regulations thereunder.
Although there do not appear to be any
issues relevant to approval or
disapproval that would be facilitated by
an oral presentation of views, data, and
arguments, the Commission will
consider, pursuant to Rule 19b–4, any
request for an opportunity to make an
oral presentation.55
Interested persons are invited to
submit written data, views, and
arguments regarding whether the
proposal should be approved or
disapproved by November 8, 2016. Any
person who wishes to file a rebuttal to
any other person’s submission must file
that rebuttal by November 22, 2016. The
Commission asks that commenters
address the sufficiency of the
Exchange’s statements in support of the
proposal, which are set forth in the
Notice,56 in addition to any other
comments they may wish to submit
about the proposed rule change. In
particular, the Commission seeks
comment on the following:
1. The proposed fund, if approved,
would be the first exchange-traded
product available on U.S. markets to
hold a digital asset such as bitcoins,
which have neither a physical form
(unlike commodities) nor an issuer that
is currently registered with any
regulatory body (unlike securities,
futures, or derivatives), and whose
fundamental properties and ownership
can, by coordination among a majority
of its network processing power, be
changed (unlike any of the above).
Moreover, as the Exchange
acknowledges in its proposal, less than
three years ago, the bitcoin exchange
then responsible for nearly threequarters of worldwide bitcoin trading
lost a substantial amount of its bitcoin
holdings through computer hacking or
fraud and failed.57 What are
commenters’ views about the current
55 Section 19(b)(2) of the Act, as amended by the
Securities Act Amendments of 1975, Public Law
94–29 (June 4, 1975), grants the Commission
flexibility to determine what type of proceeding—
either oral or notice and opportunity for written
comments—is appropriate for consideration of a
particular proposal by a self-regulatory
organization. See Securities Act Amendments of
1975, Senate Comm. on Banking, Housing & Urban
Affairs, S. Rep. No. 75, 94th Cong., 1st Sess. 30
(1975).
56 See supra note 3.
57 See Notice, supra note 3, at 25 n.19.
PO 00000
Frm 00093
Fmt 4703
Sfmt 4703
71781
stability, resilience, fairness, and
efficiency of the markets on which
bitcoina are traded? What are
commenters’ views on whether an asset
with the novel and unique properties of
a bitcoin is an appropriate underlying
asset for a product that will be traded on
a national securities exchange? What are
commenters’ views on the risk of loss
via computer hacking posed by such an
asset? What are commenters’ views on
whether an ETP based on such an asset
would be susceptible to manipulation?
2. According to the Exchange, the
Gemini Exchange Spot Price is
representative of the accurate price of a
bitcoin because of the positive pricediscovery attributes of the Gemini
Exchange marketplace. What are
commenters’ views on the manner in
which the Trust proposes to value its
holdings?
3. According to the Exchange, the
Gemini Exchange is a Digital Asset
exchange owned and operated by the
Custodian and is an affiliate of the
Sponsor. What are commenters’ views
regarding whether any potential conflict
of interest or other issue might arise due
to the relationship between entities such
as the Sponsor, the Custodian, and the
Gemini Exchange?
4. According to several commenters,
there is a need for the Exchange to
provide additional information
regarding ‘‘proof of control’’ auditing,
multisig protocols, and insurance with
respect to the bitcoins held in custody
on behalf of the Trust, in the interest of
adequate security and investor
confidence in bitcoin control. What are
commenters’ views on these
recommendations regarding additional
security, control, and insurance
measures?
5. A commenter notes that the Gemini
Exchange has relatively low liquidity
and trading volume in bitcoins and that
there is a significant risk that the
nominal ETP share price ‘‘will be
manipulated, by relatively small trades
that manipulate the bitcoin price at that
exchange.’’ 58 What are commenters’
views on the concerns expressed by this
commenter? What are commenters’
views regarding the susceptibility of the
price of the Shares to manipulation,
considering that the NAV would be
based on the spot price of a single
bitcoin exchange? What are
commenters’ views generally with
respect to the liquidity and transparency
of the bitcoin market, and thus the
suitability of bitcoins as an underlying
asset for an ETP?
6. The Exchange asserts that the
widespread availability of information
58 See
E:\FR\FM\18OCN1.SGM
Stolfi Letter, supra note 4.
18OCN1
71782
Federal Register / Vol. 81, No. 201 / Tuesday, October 18, 2016 / Notices
regarding Bitcoin, the Trust, and the
Shares, combined with the ability of
Authorized Participants to create and
redeem Baskets each Business Day,
thereby utilizing the arbitrage
mechanism, will be sufficient for market
participants to value and trade the
Shares in a manner that will not lead to
significant deviations between intraday
Best Bid/Best Ask and the Intraday
Indicative Value or between the Best
Bid/Best Ask and the NAV. In addition,
the Exchange asserts that the numerous
options for buying and selling bitcoins
will both provide Authorized
Participants with many options for
hedging their positions and provide
market participants generally with
potential arbitrage opportunities, further
strengthening the arbitrage mechanism
as it relates to the Shares. What are
commenters’ views regarding these
statements? Do commenters’ agree or
disagree with the assertion that
Authorized Participants and other
market makers will be able to make
efficient and liquid markets in the
Shares at prices generally in line with
the NAV? What are commenters’ views
on whether the relationship between the
Gemini Exchange and the Trust’s
Sponsor and Custodian might affect the
arbitrage mechanism?
Comments may be submitted by any
of the following methods:
Lhorne on DSK30JT082PROD with NOTICES
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rule-comments@
sec.gov. Please include File Number SR–
BatsBZX–2016–30 on the subject line.
Paper Comments
• Send paper comments in triplicate
to Secretary, Securities and Exchange
Commission, 100 F Street NE.,
Washington, DC 20549–1090.
All submissions should refer to File
Numbers SR–BatsBZX–2016–30. This
file number should be included on the
subject line if email is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
VerDate Sep<11>2014
13:19 Oct 17, 2016
Jkt 241001
provisions of 5 U.S.C. 552, will be
available for Web site viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE.,
Washington, DC 20549, on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of these
filings also will be available for
inspection and copying at the principal
office of the Exchange. All comments
received will be posted without change;
the Commission does not edit personal
identifying information from
submissions. You should submit only
information that you wish to make
available publicly. All submissions
should refer to File Number SR–
BatsBZX–2016–30 and should be
submitted on or before November 8,
2016. Rebuttal comments should be
submitted by November 22, 2016.
invest in FBM Holdings, LLC. Therefore
this transaction is considered financing
an Associate, requiring prior SBA
exemption.
Notice is hereby given that any
interested person may submit written
comments on the transaction, within
fifteen days of the date of this
publication, to the Associate
Administrator for Investment, U.S.
Small Business Administration, 409
Third Street SW., Washington, DC
20416.
Dated: September 28, 2016.
Mark L. Walsh,
Associate Administrator for Office of
Investment and Innovation.
[FR Doc. 2016–25078 Filed 10–17–16; 8:45 am]
BILLING CODE 8025–01–P
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.59
Robert W. Errett,
Deputy Secretary.
SMALL BUSINESS ADMINISTRATION
[FR Doc. 2016–25082 Filed 10–17–16; 8:45 am]
AGENCY:
BILLING CODE 8011–01–P
SMALL BUSINESS ADMINISTRATION
[License No. 05/05–0315]
Northcreek Mezzanine Fund II, L.P.;
Notice Seeking Exemption Under
Section 312 of the Small Business
Investment Act, Conflicts of Interest
Notice is hereby given that Northcreek
Mezzanine Fund II, L.P., 312 Walnut
Street, Suite 2310 Cincinnati, OH 45202,
a Federal Licensee under the Small
Business Investment Act of 1958, as
amended (‘‘the Act’’), in connection
with the financing of a small concern,
has sought an exemption under Section
312 of the Act and Section 107.730,
Financings which Constitute Conflicts
of Interest of the Small Business
Administration (‘‘SBA’’) Rules and
Regulations (13 CFR 107.730).
Northcreek Mezzanine Fund I, L.P. and
Northcreek Mezzanine Fund II, L.P.
propose to provide debt and equity
financing to FBM Holdings LLC, 100
Winners Circle, Brentwood, TN 37027.
The financing is brought within the
purview of § 107.730(a)(2) of the
Regulations because Northcreek
Mezzanine Fund I, L.P. is currently
invested in FBM Holdings, LLC and
because of its level of ownership, FBM
Holdings LLC is an Associate.
Northcreek Mezzanine Fund I, L.P. and
Northcreek Mezzanine Fund II, L.P. are
also Associates and are seeking to co59 17
PO 00000
CFR 200.30–3(a)(57).
Frm 00094
Fmt 4703
Sfmt 4703
[Disaster Declaration #14907 and #14908]
IOWA Disaster #IA–00067
U.S. Small Business
Administration
ACTION: Notice
This is a notice of an
Administrative declaration of a disaster
for the State of IOWA dated 10/11/2016.
Incident: Severe Weather and
Flooding
Incident Period: 09/21/2016 through
10/03/2016
EFFECTIVE DATE: 10/11/2016
Physical Loan Application Deadline
Date: 12/12/2016.
Economic Injury (EIDL) Loan
Application Deadline Date: 07/11/2017.
ADDRESSES: Submit completed loan
applications to: U.S. Small Business
Administration, Processing and
Disbursement Center, 14925 Kingsport
Road, Fort Worth, TX 76155.
FOR FURTHER INFORMATION CONTACT: A.
Escobar, Office of Disaster Assistance,
U.S. Small Business Administration,
409 3rd Street SW., Suite 6050,
Washington, DC 20416.
SUPPLEMENTARY INFORMATION: Notice is
hereby given that as a result of the
Administrator’s disaster declaration,
applications for disaster loans may be
filed at the address listed above or other
locally announced locations.
The following areas have been
determined to be adversely affected by
the disaster:
Primary Counties: Butler.
Contiguous Counties: Iowa.
Black Hawk, Bremer, Cerro Gordo,
Chickasaw, Floyd, Franklin,
Grundy, Hardin.
The Interest Rates are:
SUMMARY:
E:\FR\FM\18OCN1.SGM
18OCN1
Agencies
[Federal Register Volume 81, Number 201 (Tuesday, October 18, 2016)]
[Notices]
[Pages 71778-71782]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-25082]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-79084; File No. SR-BatsBZX-2016-30]
Self-Regulatory Organizations; Bats BZX Exchange, Inc.; Order
Instituting Proceedings To Determine Whether To Approve or Disapprove a
Proposed Rule Change to BZX Rule 14.11(e)(4), Commodity-Based Trust
Shares, To List and Trade Winklevoss Bitcoin Shares Issued by the
Winklevoss Bitcoin Trust
October 12, 2016.
On June 30, 2016, Bats BZX Exchange, Inc. (``BZX'' or ``Exchange'')
filed with the Securities and Exchange Commission (``Commission''),
pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934
(``Act'') \1\ and Rule 19b-4 thereunder,\2\ a proposed rule change to
list and trade Winklevoss Bitcoin Shares (``Shares'') issued by the
Winklevoss Bitcoin Trust (``Trust'') under BZX Rule 14.11(e)(4). The
proposed rule change was published for comment in the Federal Register
on July 14, 2016.\3\
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Securities Exchange Act Release No. 78262 (Jul. 8,
2016), 81 FR 45554 (``Notice'').
---------------------------------------------------------------------------
The Commission has received six comment letters on the proposed
rule change.\4\ On August 23, 2016, pursuant
[[Page 71779]]
to Section 19(b)(2) of the Act,\5\ the Commission designated a longer
period within which to approve the proposed rule change, disapprove the
proposed rule change, or institute proceedings to determine whether to
disapprove the proposed rule change.\6\ This order institutes
proceedings under Section 19(b)(2)(B) of the Act \7\ to determine
whether to approve or disapprove the proposed rule change.
---------------------------------------------------------------------------
\4\ See Letters from Robert D. Miller, VP Technical Services,
RKL eSolutions (July 11, 2016) (``Miller Letter''); Jorge Stolfi,
Full Professor, Institute of Computing UNICAMP (July 13, 2016)
(``Stolfi Letter''); Guillaume Lethuillier (July 26, 2016)
(``Lethuillier Letter''); Michael B. Casey (July 31, 2016) (``Casey
Letter''); Erik A. Aronesty, Sr. Software Engineer, Bloomberg LP
(Aug. 2, 2016) (``Aronesty Letter''); and Dan Anderson (Aug. 27,
2016) (``Anderson Letter''). All comments on the proposed rule
change are available on the Commission's Web site at: https://www.sec.gov/comments/sr-batsbzx-2016-30/batsbzx201630.shtml.
\5\ 15 U.S.C. 78s(b)(2).
\6\ See Securities Exchange Act Release No. 78653, 81 FR 59256
(Aug. 29, 2016). The Commission designated October 12, 2016, as the
date by which it should approve, disapprove, or institute
proceedings to determine whether to disapprove the proposed rule
change.
\7\ 15 U.S.C. 78s(b)(2)(B).
---------------------------------------------------------------------------
I. Summary of the Proposal \8\
---------------------------------------------------------------------------
\8\ The Commission notes that additional information regarding
the Trust and the Shares, including investment objectives, risks,
creation and redemption procedures, fees, portfolio holdings
disclosure policies, calculation of NAV, distributions, and taxes,
as well as additional background information about bitcoins and the
Bitcoin network, including information relating to Bitcoin network
operations, bitcoin transfers and transactions, cryptographic
security used in the Bitcoin network, Bitcoin mining and creation of
new bitcoins, the mathematically controlled supply of bitcoins,
modifications to the Bitcoin protocol, among other things, can be
found in the Notice (see supra note 3) and the registration
statement filed with the Commission on Form S-1 (File No. 333-
189752) under the Securities Act of 1933 (``Registration
Statement''), as applicable.
---------------------------------------------------------------------------
The Exchange proposes to list and trade the Shares under BZX Rule
14.11(e)(4), which governs the listing and trading of Commodity-Based
Trust Shares on the Exchange.\9\ The Shares, which will be registered
with the Commission by means of the Trust's Registration Statement,\10\
represent units of fractional undivided beneficial interest in and
ownership of the Trust. Digital Asset Services, LLC will be the sponsor
of the Trust (``Sponsor''). Gemini Trust Company, LLC, the custodian of
the Trust (``Custodian''), will hold the deposited bitcoins on behalf
of the Trust in a segregated custody account. The Exchange has
represented that the Custodian will use its proprietary and patent-
pending offline (i.e., air-gapped) cold-storage system to store the
Trust's bitcoins.\11\
---------------------------------------------------------------------------
\9\ See BZX Rule 14.11(e)(4)(C) (permitting the listing and
trading of ``Commodity-Based Trust Shares,'' defined as a security
(a) that is issued by a trust that holds a specified commodity
deposited with the trust; (b) that is issued by such Trust in a
specified aggregate minimum number in return for a deposit of a
quantity of the underlying commodity; and (c) that, when aggregated
in the same specified minimum number, may be redeemed at a holder's
request by such Trust which will deliver to the redeeming holder the
quantity of the underlying commodity).
\10\ See Registration Statement, supra note 8. The Exchange
states that the most recent amendment to the Registration Statement
was filed on June 29, 2016, and that the Registration Statement will
be effective as of the date of any offer and sale pursuant to the
Registration Statement.
\11\ According to the Exchange, the Custodian is an affiliate of
the Sponsor and a New York State-chartered limited liability trust
company that operates under the direct supervision and regulatory
authority of the New York State Department of Financial Services.
The Trust's public Bitcoin addresses are established by the
Custodian using its proprietary hardware and software security
technology. The Trust will employ security procedures, described in
greater detail in the Notice and the Registration Statement, to
safeguard the bitcoin assets of the Trust. See Notice and
Registation Statement, supra notes 3 and 8, respectively.
---------------------------------------------------------------------------
According to the Exchange, the Trust will hold only bitcoins as an
asset.\12\ The investment objective of the Trust is for the Shares to
track the price of bitcoins, as measured by the spot price at 4:00 p.m.
Eastern time on the Gemini Exchange \13\ each day the Exchange is open
for trading, minus the Trust's liabilities (which include accrued but
unpaid fees and expenses). On each business day, the Trust's
administrator will use the Gemini Exchange spot price as measured at
4:00 p.m. Eastern time to calculate the Trust's net asset value
(``NAV''). The Trust will issue and redeem the Shares in ``Baskets''
only to certain Authorized Participants on an ongoing basis.\14\
Creation Baskets will be distributed to the Authorized Participants by
the Trust in exchange for the delivery to the Trust of the appropriate
number of bitcoins (i.e., bitcoins equal in value to the value of the
Shares being purchased). On a redemption, the Trust will distribute
bitcoins equal in value to the value of the Shares being redeemed to
the redeeming Authorized Participant in exchange for the delivery to
the Trust of one or more Baskets. On each business day, the value of a
Basket for a creation transaction and the value of a Basket for a
redemption transaction will be equal to one another (i.e., each Basket
will consist of 50,000 Shares, and the value of the Basket will be
equal to the value of 50,000 Shares at the NAV per Share on that day).
---------------------------------------------------------------------------
\12\ As described in greater detail in the Notice and the
Registration Statement, a bitcoin (with a lower case ``b'') is a
digital asset that is based on the decentralized, open-source
protocol of the peer-to-peer Bitcoin computer network. The Bitcoin
network (with a capital ``B'') hosts the decentralized public
transaction ledger, known as the ``Blockchain,'' on which all
bitcoins are recorded. See Notice and Registation Statement, supra
notes 3 and 8, respectively.
\13\ The Gemini Exchange is a digital-asset exchange owned and
operated by the Custodian and is an affiliate of the Sponsor.
\14\ Each Basket will consist of 50,000 Shares, and the value of
the Basket will be equal to the value of 50,000 Shares at their NAV
per Share on that day.
---------------------------------------------------------------------------
II. Summary of Comment Letters
The Commission has received six comment letters on the proposed
rule change.\15\ The following is a summary of those letters.
---------------------------------------------------------------------------
\15\ See supra note 4 and accompanying text.
---------------------------------------------------------------------------
A. Timing of the Proposal and Investor Access to Bitcoin
One commenter states that the proposal is a timely opportunity for
the Exchange and investors, and that the proposal will allow investors
to invest in the technology without having to deal with the complexity
of holding bitcoins directly.\16\ Another commenter states that it
supports the goals of the Trust and finds the proposal to be
appropriate and timely, noting that Bitcoin is in a pivotal year and is
maturing, and noting that the average number of daily Bitcoin
transactions is currently 200,000, that more than 350,000 unique
addresses are being used to hold bitcoins,\17\ and that the Bitcoin
miners (who validate transaction blocks through computational hashes)
conduct more than a billion hashes per second.\18\ In addition, the
commenter states that, in practice, while using Bitcoin may appear
complex and forbidding, based on fear of theft and concerns about legal
and tax issues, among other things, the Trust can help a whole category
of people to gain access, albeit indirectly, to Bitcoin.\19\
---------------------------------------------------------------------------
\16\ See Miller Letter, supra note 4.
\17\ Additional information about Bitcoin addresses and storage,
mining, bitcoin transfers, and the Blockchain, among other things,
can be found in the Notice. See Notice, 81 FR at 45556-45561, supra
note 3.
\18\ See Lethuillier Letter at 1-2, supra note 4.
\19\ See id. at 2.
---------------------------------------------------------------------------
B. Need for Additional Control and Security Measures
With respect to security measures to be implemented by the Trust,
one commenter recommends that additional steps mandating ``proof of
control'' audits be employed to protect the consumers of this ETP.\20\
Specifically, the commenter recommends a monthly ``proof of control''
audit of all of the Trust's bitcoins to be performed by the Custodian
and provided to the Sponsor, who should display the signed messages on
its Web site to publicly demonstrate proof of control over the bitcoins
held by the Trust.\21\ According to this commenter, the message to be
signed can be the mined hash of a
[[Page 71780]]
predetermined block height, which is guaranteed to be both easily
verifiable and unknown in advance,\22\ and the signatures can be
created with the private keys still in cold storage and air-gapped.\23\
This commenter notes that publicly identifying the addresses holding
the bitcoins adds no risk to them being stolen due to the nature of
Bitcoin.\24\ According to the commenter, the bitcoins remain secure
from even quantum attack as the public key is never revealed, no
additional risk is incurred by publishing the proof-of-control audit,
and opening control to public audit vastly increases confidence in
possession and control of the underlying asset.\25\ In addition, the
commenter notes that publishing the proof-of-control audit on a monthly
basis would not place an undue burden on either the Sponsor or
Custodian, as less-regular audits are scheduled in any event.\26\
---------------------------------------------------------------------------
\20\ See Casey Letter, supra note 4.
\21\ See id. at 2.
\22\ See id.
\23\ See id.
\24\ See id.
\25\ See id.
\26\ See id.
---------------------------------------------------------------------------
Another commenter addressed proof-of-control audits, adding that,
unlike with non[hyphen]digital assets, an ``audit'' of assets in
bitcoins can be low cost, public, and automated, and that there is no
legitimate reason to maintain secrecy of the holdings involved in a
trust or exchange.\27\ This commenter notes that a well[hyphen]managed
trust should be able to trivially update its proof of assets at least
once every day, if not more often (every time a bitcoin is moved or
acquired).\28\ This commenter proposes that the Commission require that
any trust holding bitcoins either (i) maintain insurance on its assets,
or (ii) allow for public, daily audit of funds. Without one of those
two measures, the commenter states, investors in a bitcoin trust cannot
be reasonably assured that their investment is being soundly
custodied.\29\ The commenter concludes by stating that, given the
nature of bitcoins as electronic assets, a public and daily proof,
rather than the stated provisions for private audits, should also be
considered.\30\
---------------------------------------------------------------------------
\27\ See Aronesty Letter, supra note 4.
\28\ See id.
\29\ See id.
\30\ See id.
---------------------------------------------------------------------------
Another commenter states that, according to the proposed rule
change, the Custodian's Cold Storage System utilizes multiple-signature
(``Multisig'') technology with an ``M-of-N'' signing design that
requires a signature from more than one (1) Signer (but fewer than the
full complement of potential Signers) in order to move the Trust's
bitcoins.\31\ The commenter recommends amending the proposal in order
to unambiguously specify the M-of-N signing design used to secure the
Custodian's Cold Storage System and to require the Trust to notify
interested third parties, such as the Commission or, as the case may
be, the Trust's insurer, of any modification of the Multisig
characteristics in the future.\32\ Specifically, this commenter notes
that the proposed rule change fails to provide a meaningful description
of the security level of the storage system Multisig.\33\ The proposal,
the commenter asserts, ``merely defines what a [M]ultisig is, in
general, while only excluding the extreme cases M = 1, insecure, and M
= N, unpractical.'' \34\ The commenter states that the present signing
design is complicated by the fact that the Signers, which are hardware
devices, are activated by Signatories, which are human beings.\35\ The
commenter states that, as result, the given definition is overly
abstract and incomplete. Because the signing design is critical to the
safety of the funds, the commenter asserts, ``the Trust should
communicate the following elements to the interested third parties such
as the Commission or, as the case should be, the Trust's insurer: (i)
Exact number of required Signers; (ii) Exact number of potential
Signers; (iii) detailed explanation of why the chosen M-of-N
configuration is adequate; (iv) complete list of the Signatories and
what Signer(s) they can activate; and (v) useful information related to
the Signatories' keys. . . . '' \36\ The commenter adds that the Trust
should notify the relevant persons without delay of any modification of
any of the above elements: (i) Through (iii) should be publicly
announced, and, for security reasons, (iv) and (v) should be notified
to the interested third parties only.\37\
---------------------------------------------------------------------------
\31\ Additional information about the ``M-of-N'' signing design
can be found in the Notice. See Notice, 81 FR at 45566-45567, supra
note 3.
\32\ See Lethuillier Letter at 3, supra note 4.
\33\ See id.
\34\ See id.
\35\ See id.
\36\ See id.
\37\ See id.
---------------------------------------------------------------------------
C. Need for Insurance on the Fund's Holdings
A commenter notes that ``[b]ecause safety measures cannot prevent
thefts from the outside or the inside, [and] because human rationality
is inherently bounded,'' he does not support the fact that the Trust's
bitcoins are not insured.\38\ This commenter further asserts that the
Gemini Exchange was able to discover on its own a failure to secure the
secret keys that would maintain the safe custody of bitcoins.\39\
---------------------------------------------------------------------------
\38\ See Lethuillier Letter at 2-3, supra note 4.
\39\ See id.
---------------------------------------------------------------------------
D. Need for Regulation of the Bitcoin ETP Industry
One commenter states that, despite the advances in Bitcoin
development, owning and controlling bitcoins remains a highly
specialized task, which includes secure management of private keys and
``fairly advanced technological know-how.'' \40\ Because of the
difficulty and specialized knowledge required to manage bitcoins, many
investors rely on exchanges to act as custodians of their value. As a
result, the commenter believes that a Bitcoin ETP is a major milestone
and improvement and that it is crucial that the Commission regulate
this industry.\41\ The commenter concludes by noting that the concerns
regarding bitcoin security would be greatly diminished were it possible
to trade an ETP backed by bitcoins, rather than the bitcoins
themselves.\42\
---------------------------------------------------------------------------
\40\ See Anderson Letter, supra note 4.
\41\ See id.
\42\ See id.
---------------------------------------------------------------------------
E. Speculative Nature of Bitcoin as an Underlying Digital Asset
One commenter disagreed with the notion that bitcoins are
commodities; rather, the commenter likened bitcoins to be more like
``penny stock'' or shares of a ponzi scheme.\43\ The commenter notes
that the market price of a bitcoin, like that of a penny stock or ponzi
fund, is ``entirely speculative, based on expectations of traders about
future prices, which will be based on expectations of future
expectations.'' \44\ The commenter asserts that Bitcoin has the
essential characteristics of a penny stock or a pyramid scheme: The
profit of early investors comes entirely from the investment of later
ones.\45\ In the commenter's view, because bitcoins are primarily used
for investment, bitcoins should be regulated like a security, in which
case they should be regulated the same way a penny stock or ponzi fund
would be.\46\ The commenter concludes that the proposed ETF does not
add any productive mechanism to the underlying bitcoins, but rather
makes bitcoins accessible to investments funds, such as retirement
funds.\47\
---------------------------------------------------------------------------
\43\ See Stolfi Letter, supra note 4.
\44\ See id.
\45\ See id.
\46\ See id.
\47\ See id.
---------------------------------------------------------------------------
[[Page 71781]]
F. Concerns Regarding the Gemini Exchange and the Gemini Exchange Spot
Price
One commenter expresses concerns regarding the Gemini Exchange Spot
Price.\48\ Specifically, the commenter states, the nominal price of the
shares under the proposal is supposed to be tied to the market price of
bitcoins at the Gemini Exchange, which is closely tied to the ETP
proponents.\49\ In addition, the commenter states, the Gemini Exchange
has relatively low liquidity and trade volume in bitcoins.\50\ The
commenter asserts that there is a significant risk that the nominal ETP
share price ``will be manipulated, by relatively small trades that
manipulate the bitcoin price at that exchange.'' \51\
---------------------------------------------------------------------------
\48\ See id.
\49\ See id.
\50\ See id.
\51\ See id.
---------------------------------------------------------------------------
III. Proceedings To Determine Whether To Approve or Disapprove SR-
BatsBZX-2016-30 and Grounds for Disapproval Under Consideration
The Commission is instituting proceedings pursuant to Section
19(b)(2)(B) of the Act \52\ to determine whether the proposed rule
change should be approved or disapproved. Institution of such
proceedings is appropriate at this time in view of the legal and policy
issues raised by the proposed rule change. Institution of proceedings
does not indicate that the Commission has reached any conclusions with
respect to any of the issues involved. Rather, as described below, the
Commission seeks and encourages interested persons to provide comments
on the proposed rule change.
---------------------------------------------------------------------------
\52\ 15 U.S.C. 78s(b)(2)(B).
---------------------------------------------------------------------------
Pursuant to Section 19(b)(2)(B) of the Act,\53\ the Commission is
providing notice of the grounds for disapproval under consideration.
The Commission is instituting proceedings to allow for additional
analysis of the proposed rule change's consistency with Section 6(b)(5)
of the Act, which requires, among other things, that the rules of a
national securities exchange be ``designed to prevent fraudulent and
manipulative acts and practices, to promote just and equitable
principles of trade,'' and ``to protect investors and the public
interest.'' \54\
---------------------------------------------------------------------------
\53\ Id.
\54\ 15 U.S.C. 78f(b)(5).
---------------------------------------------------------------------------
IV. Procedure: Request for Written Comments
The Commission requests that interested persons provide written
submissions of their views, data, and arguments with respect to the
issues identified above, as well as any other concerns they may have
with the proposal. In particular, the Commission invites the written
views of interested persons concerning whether the proposal is
consistent with Section 6(b)(5) or any other provision of the Act, or
the rules and regulations thereunder. Although there do not appear to
be any issues relevant to approval or disapproval that would be
facilitated by an oral presentation of views, data, and arguments, the
Commission will consider, pursuant to Rule 19b-4, any request for an
opportunity to make an oral presentation.\55\
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\55\ Section 19(b)(2) of the Act, as amended by the Securities
Act Amendments of 1975, Public Law 94-29 (June 4, 1975), grants the
Commission flexibility to determine what type of proceeding--either
oral or notice and opportunity for written comments--is appropriate
for consideration of a particular proposal by a self-regulatory
organization. See Securities Act Amendments of 1975, Senate Comm. on
Banking, Housing & Urban Affairs, S. Rep. No. 75, 94th Cong., 1st
Sess. 30 (1975).
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Interested persons are invited to submit written data, views, and
arguments regarding whether the proposal should be approved or
disapproved by November 8, 2016. Any person who wishes to file a
rebuttal to any other person's submission must file that rebuttal by
November 22, 2016. The Commission asks that commenters address the
sufficiency of the Exchange's statements in support of the proposal,
which are set forth in the Notice,\56\ in addition to any other
comments they may wish to submit about the proposed rule change. In
particular, the Commission seeks comment on the following:
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\56\ See supra note 3.
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1. The proposed fund, if approved, would be the first exchange-
traded product available on U.S. markets to hold a digital asset such
as bitcoins, which have neither a physical form (unlike commodities)
nor an issuer that is currently registered with any regulatory body
(unlike securities, futures, or derivatives), and whose fundamental
properties and ownership can, by coordination among a majority of its
network processing power, be changed (unlike any of the above).
Moreover, as the Exchange acknowledges in its proposal, less than three
years ago, the bitcoin exchange then responsible for nearly three-
quarters of worldwide bitcoin trading lost a substantial amount of its
bitcoin holdings through computer hacking or fraud and failed.\57\ What
are commenters' views about the current stability, resilience,
fairness, and efficiency of the markets on which bitcoina are traded?
What are commenters' views on whether an asset with the novel and
unique properties of a bitcoin is an appropriate underlying asset for a
product that will be traded on a national securities exchange? What are
commenters' views on the risk of loss via computer hacking posed by
such an asset? What are commenters' views on whether an ETP based on
such an asset would be susceptible to manipulation?
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\57\ See Notice, supra note 3, at 25 n.19.
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2. According to the Exchange, the Gemini Exchange Spot Price is
representative of the accurate price of a bitcoin because of the
positive price-discovery attributes of the Gemini Exchange marketplace.
What are commenters' views on the manner in which the Trust proposes to
value its holdings?
3. According to the Exchange, the Gemini Exchange is a Digital
Asset exchange owned and operated by the Custodian and is an affiliate
of the Sponsor. What are commenters' views regarding whether any
potential conflict of interest or other issue might arise due to the
relationship between entities such as the Sponsor, the Custodian, and
the Gemini Exchange?
4. According to several commenters, there is a need for the
Exchange to provide additional information regarding ``proof of
control'' auditing, multisig protocols, and insurance with respect to
the bitcoins held in custody on behalf of the Trust, in the interest of
adequate security and investor confidence in bitcoin control. What are
commenters' views on these recommendations regarding additional
security, control, and insurance measures?
5. A commenter notes that the Gemini Exchange has relatively low
liquidity and trading volume in bitcoins and that there is a
significant risk that the nominal ETP share price ``will be
manipulated, by relatively small trades that manipulate the bitcoin
price at that exchange.'' \58\ What are commenters' views on the
concerns expressed by this commenter? What are commenters' views
regarding the susceptibility of the price of the Shares to
manipulation, considering that the NAV would be based on the spot price
of a single bitcoin exchange? What are commenters' views generally with
respect to the liquidity and transparency of the bitcoin market, and
thus the suitability of bitcoins as an underlying asset for an ETP?
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\58\ See Stolfi Letter, supra note 4.
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6. The Exchange asserts that the widespread availability of
information
[[Page 71782]]
regarding Bitcoin, the Trust, and the Shares, combined with the ability
of Authorized Participants to create and redeem Baskets each Business
Day, thereby utilizing the arbitrage mechanism, will be sufficient for
market participants to value and trade the Shares in a manner that will
not lead to significant deviations between intraday Best Bid/Best Ask
and the Intraday Indicative Value or between the Best Bid/Best Ask and
the NAV. In addition, the Exchange asserts that the numerous options
for buying and selling bitcoins will both provide Authorized
Participants with many options for hedging their positions and provide
market participants generally with potential arbitrage opportunities,
further strengthening the arbitrage mechanism as it relates to the
Shares. What are commenters' views regarding these statements? Do
commenters' agree or disagree with the assertion that Authorized
Participants and other market makers will be able to make efficient and
liquid markets in the Shares at prices generally in line with the NAV?
What are commenters' views on whether the relationship between the
Gemini Exchange and the Trust's Sponsor and Custodian might affect the
arbitrage mechanism?
Comments may be submitted by any of the following methods:
Electronic Comments
Use the Commission's Internet comment form (https://www.sec.gov/rules/sro.shtml); or
Send an email to rule-comments@sec.gov. Please include
File Number SR-BatsBZX-2016-30 on the subject line.
Paper Comments
Send paper comments in triplicate to Secretary, Securities
and Exchange Commission, 100 F Street NE., Washington, DC 20549-1090.
All submissions should refer to File Numbers SR-BatsBZX-2016-30. This
file number should be included on the subject line if email is used. To
help the Commission process and review your comments more efficiently,
please use only one method. The Commission will post all comments on
the Commission's Internet Web site (https://www.sec.gov/rules/sro.shtml). Copies of the submission, all subsequent amendments, all
written statements with respect to the proposed rule change that are
filed with the Commission, and all written communications relating to
the proposed rule change between the Commission and any person, other
than those that may be withheld from the public in accordance with the
provisions of 5 U.S.C. 552, will be available for Web site viewing and
printing in the Commission's Public Reference Room, 100 F Street NE.,
Washington, DC 20549, on official business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of these filings also will be available
for inspection and copying at the principal office of the Exchange. All
comments received will be posted without change; the Commission does
not edit personal identifying information from submissions. You should
submit only information that you wish to make available publicly. All
submissions should refer to File Number SR-BatsBZX-2016-30 and should
be submitted on or before November 8, 2016. Rebuttal comments should be
submitted by November 22, 2016.
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\59\ 17 CFR 200.30-3(a)(57).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\59\
Robert W. Errett,
Deputy Secretary.
[FR Doc. 2016-25082 Filed 10-17-16; 8:45 am]
BILLING CODE 8011-01-P