Intriguing public comments on the Bitcoin ETF proposal

by Gemma Evans via StockSnap
by Gemma Evans via StockSnap

While you have most likely heard about the upcoming decision by the SEC on whether or not to approve the proposed Winklevoss Bitcoin ETF (given that most mainstream press is attributing the recent bitcoin price increase to positive expectations), what you maybe didn’t know is this:

Comments sent to the SEC advising on this decision are public. Anyone can tell the SEC what they think. And you can see what they wrote.

It’s fascinating, especially since some sector influencers have sent in their opinions.

For instance, Joshua Lim and Dan Matuszewski of Circle Internet Financial write:

“Both institutional and individual investors stand to benefit from the potential listing of the Winklevoss Bitcoin Shares. Such a listing would create a trusted, safe, transparent and regulated entry point into this maturing asset class, which is growing in importance as an investible store of value globally.”

Chris Burniske of ARK Invest (manager of the first ETF to invest in bitcoin) disagrees:

“After thorough examination, we think it would be premature to launch a bitcoin ETF because we do not believe the bitcoin markets are liquid enough to support an open-end fund, or that an ecosystem of institutional grade infrastructure players is yet available to support such a product.”

Attorney and professor of law Philip Chronakis is in favour:

“Denial of the proposed rule will not stop Bitcoin’s progress, but approval of the proposed rule, and the underlying COIN ETF, will put the SEC in the ideal position to oversee Bitcoin’s development as an investment asset – and provide fair, broad-based investment opportunities for not only the connected (or technologically savvy) few, but to all Americans who deserve the same chance to benefit from this technological breakthrough and financial opportunity.”

Michael Lee is against, and sheds some interesting light on recent price movements:

“The price of bitcoin is being heavily manipulated at this very moment on exchanges which somehow began the day of the SEC’s Feb 14th meeting but before the news of this very meeting was released to the public. Currently, we are at all time highs based on rumors and speculation on this meeting alone and it feels like we are again in a price bubble which could result in a huge loss for new investors. An approval of the COIN ETF at this time would only exacerbate this bubble and result in a price crash even before ETF trading will be fully available.”

Ben Elron uses stirring language:

“The Bitcoin ETF represents a rare opportunity for our country to embrace a revolutionary financial technology (the blockchain) with relatively low risk. Indeed, if approved, this fund would arguably be the most transparent, efficient and secure instrument ever offered – requisites enumerated in the Commission’s founding charters.

Blockchain is the future. If American regulators fail to embrace it, others will, and we will then be forced to follow. Let us lead once again.”

And in a somewhat quirky and impassioned comment, Diego Tomaselli implores:

“We understand your role is to protect the American Investor.

Please, just don’t forget to protect also the American Spirit.”

The magnitude of the price bump that approval would generate is uncertain. Given that the bitcoin price has increased by more than 18% since the beginning of the year, a case could be made that approval is already largely priced in.

Today CoinDesk revealed that GABI (currently one of the largest institutional investors in bitcoin) believes that the market is over-optimistic and is therefore reducing its holdings. Since early yesterday morning, the price has been falling, and at time of writing is down almost 8%.

Whatever happens over the next few days, it’s safe to assume that the bitcoin price will be volatile. Which may not be what you want in the underlying asset of an ETF.

That said, I’m hoping that it gets approved. 🙂

Bitcoin ETF approval: the long game

by Louis Blythe for Unsplash - Bitcoin ETF approval
by Louis Blythe for Unsplash

The looming decision by the US Securities Exchange Commission (SEC) is, according to market analysts, putting wind under the bitcoin price sails. Market attention and media headlines seem to be focusing on the short-term impact. A pity… they’re missing out on a more interesting story.

A brief summary of the situation so far: in June 2013, Cameron and Tyler Winklevoss – the owners of the New York-based Gemini bitcoin exchange – submitted a proposal to the SEC for a bitcoin exchange traded fund (ETF) to list on Nasdaq. Since then, the Winklevoss Bitcoin Trust proposal has gone through several amendments, including switching to the BATS exchange (newer, and allegedly more technologically advanced) and establishing pricing mechanisms and custodianship procedures. After seeking public comment and using up all the deadline extensions available, the SEC is due to make a decision on approval by March 11th.

Many doubt that it will be approved. In fact, BitMex is running a book on the outcome, which places the probability at less than 40%.

Why would the SEC say no? The decision is a complicated one, but can be broken down into three sections: the intrinsic (issues pertaining to the fund itself), the extrinsic (issues pertaining to the market) and the bigger picture.

Amongst the intrinsic considerations are the suppliers of the various services that the fund will need. The Winklevosses propose that price determination and custodianship be carried out by their Gemini exchange. In the ETF world, it is unusual for one entity to fulfil both of those functions and at the same time be the sponsor.

The SEC also has concerns about bitcoin and its market. Its recent request for information included questions about forks, immutability and hacking, which reveals uncertainty over the strength of the technology. Furthermore, most of bitcoin’s trading volume is in China and Japan, which raises the spectre of manipulation of a US asset by foreign entities.

While structure and market concerns are fundamental, the SEC is no doubt also considering abstract issues such as its own reputation, and the possible effect on financial instruments. Here’s where the more interesting long game shows itself.

The SEC’s main purpose is that of protecting investors. Supporting innovation is not on its list of priorities. Given the relative youth of bitcoin and the potential vulnerabilities of the technology (mining decentralization, accidental forks, quantum technology), the risks are high. And if the SEC approves and something negative happens, that’s their reputation shot.

So, will the SEC embrace evolution and innovation, and acknowledge that bitcoin is here to stay? If so, that would mark a precedent that could shape expectations for years to come.

Or, will the SEC play it safe and defer difficult decisions until a later date? In which case, think about the message sent to change-makers. While it’s impossible to suppress creativity, a “no” decision could send innovators scurrying to find alternative (and less-regulated) outlets.

It’s also important to think about the bitcoin market beyond the immediate impact.

The Winklevoss proposal was recently amended to increase the initial amount from $65m to $100m, which signals strong initial demand. Analysts Needham & Company estimate that $300m could pour into the fund if approved, which given the limited daily volume (US$ trading is usually under $50m/day) would push up the price. How much of that is already priced in, we don’t know. And it’s worth remembering that the estimated inflow is just that, an estimate based on the performance of other similar funds (which is tricky, given that this is a first).

If the SEC decides “no”, it’s probable that the price will fall sharply. But bitcoin has many other fundamentals in its favour, and the price is likely to find support at lower levels (how much lower, I don’t know).

So, the immediate impact, even if the ETF is approved, is uncertain. The longer-term impact, however, is clearer.

There’s the liquidity aspect. If approved, the increase in bitcoin demand will boost trading volumes overall, which will reduce volatility, making bitcoin even more attractive to investors. Most of the increase will be in the US, since the fund will be doing its trading on the Gemini exchange. This will even out the current geographical imbalance in trading volumes, and calm the unease of regulators. It’s worth noting that Gemini is one of two bitcoin exchanges to have a BitLicense, which makes it one of the most highly regulated exchanges in the world.

Beyond price and liquidity improvements, there’s the reputation. Bitcoin will go from being “something criminals use” to “something approved by the SEC”, which would add a lasting veneer of respectability. Institutions and investors, not just in the US, would start to see it as an asset class rather than a libertarian speculation.

This could rattle economists and policy makers, since bitcoin represents an alternative to the established system. But it is in line with increased interest in blockchain technology from institutions. Central banks around the world are studying cryptocurrencies, some with a view to launching their own. And the recent appointment of bitcoiner Mick Mulvaney as Trump’s Director of Office of Management and Budget could herald a shift in the official attitude.

Finally, it’s important to bear in mind that an approved bitcoin ETF would be the first “mainstream” fund to be based entirely on a digital concept, with no tangible underlying asset. This could unleash a stream of creative financial engineering which could usher in a new era of opportunity. Or, it could end up increasing market instability, especially when combined with a federal policy of more relaxed regulation of financial institutions.

So, the ramifications go well beyond a “yes” or “no” and the resulting impact on the price. The initial swings will be exhilarating or horrifying, depending on your position. But the bigger picture, which affects us all, is much more compelling.

Bitcoin volumes and volatility – now what?

trading 700

CoinDesk reported yesterday on the change in the pricing strategy of the three largest Chinese bitcoin exchanges: BTCC, Huobi and OKCoin. This weekend they announced that they were suspending their “no fee” policy and moving to a 0.2% flat fee, “in response to guidance from the People’s Bank of China”.

Today we reported on the impact of this decision on trading volumes. No surprise – they’re much lower.

A bit of background: the “no fee” model may sound like an extraordinary business strategy (not charging for your main business), but it’s actually not very different from the “Freemium” models we see all over the place, in which most stuff is free, but some things not. The basic service is available to anyone, but for better content or service, you pay something. It’s an old strategy, even used by physical retail outlets – to get you in the store, they price some products so cheaply that they lose money on them. These are called “loss leaders”. The idea is that while you’re there, you’ll buy other stuff as well, and the store will make money there.

In the case of bitcoin exchanges, they don’t make money on the trades they execute, but they do charge a fee for entries and withdrawals. If you want to put money into your account, there’s a fee for that. If you want to take money out, also. But the trading you do in between, no charge.

The practice recently seeped into European exchanges, with London-based Coinfloor (number 25 in terms of fee-based bitcoin trading volume, according to Coinmarketcap, and the largest in the UK) announcing last week that it would adopt this pricing strategy.

The objective is to bring in liquidity. The result is to inflate volumes.

Since there is no charge for buying and selling, traders feel that they can churn holdings as much as they wish. And even small gains are worth it, especially if repeated several times during the trading day, since there is no associated monetary cost.

So, volumes are much higher under a “no fee” policy than they would be otherwise, and the PBoC regarded this as “fake volume” which added unnecessary volatility to the market.

In fact, the impact of no fees is so stark that Coinmarketcap (where I get my relative exchange volumes) only includes exchanges with fees in their main ranking (although you can get the whole list in another tab).

So, the volume hit was not a surprise. The announcement last week that the exchanges have halted margin trading (in which the exchange lends you the money to trade, which further encourages speculation) is no doubt also likely to have an impact.

The question now is: will this lower volatility? Or will it increase it?

Intuitively, less “churning” of holdings should make prices more stable. Trades are more “real” in that they are not about grasping at small gains. Positions are (in theory) held for longer, since changing them now incurs a cost. Less “fake” volumes, the PBoC’s reasoning goes, means more stable markets and less risk for non-professional investors.

But, lower volumes means lower liquidity, which means more vulnerability to swings due to large buy or sell orders. With higher liquidity, large orders have less of an impact as there are more funds available to settle those orders. Lower liquidity means that prices move more to tempt traders to take a side.

That, at least, was the argument that LedgerX gave in a CoinDesk interview yesterday. Here we have a derivatives exchange arguing that approval by the Commodity Futures Trading Commission (CFTC) would decrease bitcoin’s volume. Yes, you heard right, derivative trading can decrease volatility. Or so they say, and maybe they’re right, but I’m having a hard time getting my head around this.

The argument is that the increased liquidity from regulated bitcoin options will provide the market with a cushion to absorb large orders and avoid the price swings that usually result. My skepticism stems from the fact that it often is the need to close out derivative positions that generates these large orders in the first place, orders that often need to be filled in a hurry, at any price.

I do buy the argument that increased derivatives trading enhances price discovery, as future expected prices tend to react less to current events. And I understand that an active (and regulated) futures market can reduce the need to place large market-moving buy orders to “bet” on a certain direction – it’s cheaper and easier to buy futures contracts instead. They can also reduce the need to liquidate large positions, by “insuring” them at a relatively low cost.

However, here’s what has me worried: with derivatives, it is not very costly to accumulate large enough a position to benefit from sharp moves. It is conceivable that a speculator could accumulate a ton of puts, and then attack the bitcoin blockchain. The potential profit from the derivatives position from a sharp plunge in price could outweigh the cost of the attack.

And, I am not yet convinced by the increased liquidity argument. It could reduce volatility, but it could also increase it by encouraging speculative positions. That seems to be the PBoC’s position, that “fake” volumes are not good for the market nor for its investors.

As always, time will tell. And no doubt, other factors will throw in additional complications. Attributing changes in trends to any one announcement, in bitcoin as in life, tends to miss the bigger picture.


What is a maker-taker market?

After looking into how a bitcoin wallet works, I felt that it was time to take the exchanges apart. But I kept coming up against the phrase “maker-taker trading”. You probably know what it is, but I didn’t, so I hit the search bar and this is what I found:

Back when I worked in the financial markets, exchanges were places where traders bought at one price and sold at another and hopefully made money on the difference. The traders paid a fee for the privilege, but customer orders (end buyers such as private individuals or investment funds) didn’t, and jumped to the head of the queue.

fx trading

Things have changed. The advent of high frequency trading and the proliferation of illiquid securities and assets led to the need to increase trading liquidity in certain markets.

“Maker taker” trading was designed to incentivize market makers (those who post possible trades) to provide liquidity, so that market takers (those that accept those trades) would have an assurance that their orders would be met. Market makers are those who are willing to buy or sell at a certain price. They publish their willingness. Market takers are those who actively want to buy or sell. They go looking for a suitable published proposed trade, and accept it. Market makers provide the gasoline for the market. Market takers step on the pedal so that the gasoline is used up.

Not all bitcoin exchanges have adopted this trading system, but it seems that most of the large ones have, including Kraken, Coinbase, Coinfloor, and itBit. In fact, itBit charges no maker fees at all, and Gemini, Coincheck and BTCC offer to pay (= a net rebate) dealers for posting bids and offers.

In the securities industry, maker-taker trading is coming under fire for allegedly distorting market pricing, and for possibly creating conflicts of interest. Most stock exchanges require brokers to route their clients’ trades to the best available price. Under the maker-taker system, market “makers” are more likely to take their bids and offers to the exchange that gives the best rebate, rather than the best price. Plus, effectively “paying” people to trade goes against the free market philosophy underpinning most official trading forums. And the model can lead to different settling prices than on a fee-based exchange.

Yet it is unlikely that this unease will spill over into bitcoin exchanges just yet. At the moment, liquidity seems to be a priority, and the maker-taker system encourages liquidity by incentivizing the posting of trades. As liquidity increases, it’s likely that the maker-taker model will come under more scrutiny. But by then it’s likely that trading technology will have advanced to the point that exchanges and traders need to operate under different rules anyway.