First Bitcoin Capital Today Advised the SEC of its Support for the Pending Bitcoin and Ethereum Exchange Traded Funds (ETF)
May 05 2017 - 10:30AM
Access Wire
VANCOUVER, BC / ACCESSWIRE / May 5, 2017 /
First Bitcoin Capital Corp. (OTC PINK: BITCF):
Hon. Michael S. Piwowar, Acting Chairman
Hon. Kara M. Stein, Commissioner
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
May 4. 2017
Re: File No. SR-BatsBZX-2016-30
Dear Commissioners Piwowar and Stein,
We, First Bitcoin Capital Corp respectfully submit this letter
in support of the Proposed Rule Change to Bats-BZX Rule
14.11(e)(4), and more generally, in support of the Securities and
Exchange Commission's consideration of the underlying request to
create a publicly traded Exchange Traded Fund for the commodity of
Bitcoin.
As the leading public company in the Bitcoin space, we would
like to present our conclusive research for your kind
consideration.
Based on this research, the primary way that the SEC protects
the public is through requiring adequate and accurate disclosures.
In this regard, it appears that COIN has overwhelmingly met those
requirements and the SEC has not raised the adequacy and/or
accuracy of the COIN disclosures as an issue. On the other hand,
the concern about the lack of regulation is covered thereby giving
potential speculators and investors this knowledge to fulfill the
logic behind the SEC's adequate and accurate disclosure
requirements.
The SEC revealed that it fears the ability (presumably of some
billionaire) to manipulate Bitcoin as a commodity, yet that would
likely be more difficult to accomplish than the Hunt Brothers
achieved in their attempt to monopolize silver.
The significant supply and demand and diversity of market
factors driving BTC would easily make such a feat nearly, if not,
impossible.
Imagine trying to move in and out of 300 markets worldwide
needing to wield hundreds of millions of dollars to have any
influence and to what avail? So, say some currency manipulator like
Soros tried this, he could just as easily lose his shirt and how
long could he sustain such an operation? Apparently, it would be in
an effort to buy and sell shares of the EFT named COIN for a
profit. If the manipulator were successful in controlling BTC in
the markets, there would be no need to utilize the EFT to achieve
that goal.
Recent history has already given us a clear view of how COIN
would look and trade in a similar entity trading as Global Bitcoin
Trust (GBTC) on the OTCQX found at
http://www.otcmarkets.com/stock/GBTC/quote where today's price
movements on a smaller scale reflected the substantial increases in
BTC's rising price and volume.
Consider for example that $959,301,000 worth of BTC has traded
in the past 24 hours (at the time of writing this) according to
http://coinmarketcap.com/currencies/bitcoin/ and this covers dozens
of exchanges around the world trading in at least 300 fiat and
cryptocurrencies that charge fees. It does not include those
exchanges that are commission free, nor those that have not
provided their API to coinmarketcap.com.
Another aspect that makes Bitcoin less susceptible to
manipulation is the fact that each transference from wallet to
wallet of Bitcoin can be seen on an open public ledger known as a
blockchain.
The example of the Hunt Brothers is relevant because worldwide
silver daily trading volume is similar in size to Bitcoin, and was
mostly an unregulated commodity decades ago- similar to Bitcoin
today.
Governments around the world are beginning to regulate trading
of Bitcoin, for example, Japan began regulating BTC last month. The
New York banking authority began regulating bitcoin exchanges and
FINCEN requires registration for Bitcoin exchanges in the USA.
Gemini, a regulated exchange affiliated with COIN through their
founders, the Winklevoss Twins, accounts for a very small amount of
Bitcoin trading and would not be a good vehicle for manipulation as
inexplicably envisioned by the SEC.
Imagine if the conclusion were made that due to the Hunt
Brothers attempt to corner the silver market that silver could not
be the basis of a commodity based Exchange Traded Fund?
Similar arguments could be made for the EtherIndex Ether Trust
first filed in July 2016, seeking to launch an ETF backed by a
cache of ethers on the NYSE Arca exchange as well as any other
leading altcoins that would enter into an EFT.
Thank you for your kind consideration.
Respectfully submitted,
Simon Rubin, Chairman of the Board
FIRST BITCOIN CAPITAL CORP.
SOURCE: First Bitcoin Capital Corp.
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