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VanEck Responds to SEC’s Bitcoin ETF Concerns In New Letter

Vaneck responds to sec’s bitcoin etf concerns in new letter

VanEck Responds to SEC’s Bitcoin ETF Concerns In New Letter


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Money management firm VanEck has responded to the SEC’s concerns over bitcoin exchange-traded funds (bitcoin ETF) in a letter to the regulator made public on the agency’s website.

Addressed to Dalia Blass, director of the SEC’s division of investment management, the letter tackles the five points of order from the SEC’s previous communication with the industry, namely: valuation, liquidity, custody, arbitrage, and potential manipulation.

Valuation

On this issue, the company states that it does not see valuation as a “novel issue” for a futures-based bitcoin ETF because it is already common practice to use futures to build an investment profile in an asset.

The valuation of such contracts VanEck says, is a well-established practice, with more than 100 exchange traded products currently listed on U.S. exchanges basing their value on futures contracts. In the company’s opinion, prices from CBOE and CME are enough to adequately determine an ETF’s net asset value (NAV).

Liquidity

Responding to concerns about the proposed ETF’s liquidity, VanEck points out that the bitcoin market is a very liquid one, with an average trading spread of less than five basis points. It also makes the point that the bitcoin futures market has been efficient against the physical bitcoin market, with the total volume of the CBOE and CME coming up to $200 million.

The company also mentions that it has no intention for its proposed ETF to invest in physically-settled bitcoin futures contracts should they become available.

Custody

Cold storage vault
Source: shutterstock

Moving on to custody, VanEck restates that its ETF will not invest in physically settled bitcoin contracts, but it could engage with market players to find a solution to satisfy direct custody requirements. Until such arrangements are possible and viable, it says, the status quo remains in effect.

Arbitrage

Speaking on the subject of arbitrage trading, VanEck’s letter states that the diversified, decentralised nature of bitcoin exchange activities allows for arbitrage trading due to price differentials and inefficiencies across different exchange platforms.

In VanEck’s opinion, bitcoin markets are not significantly more volatile than gold miner stocks or comparable equities.

An excerpt reads as follows:

“We believe that neither the volatility nor the current volume in the bitcoin futures market will inhibit the creation and redemption process by authorized participants and that these creations and redemptions will keep the proposed ETF’s market price in line with its NAV.”

Potential Manipulation and Other Risks

In the company’s opinion, such risks with its ETF are overwhelmingly mitigated by its nature as a regulated product traded on a US exchange.

A quote from the letter reads:

“While one cannot rule out manipulation in the underlying spot market, we believe that, due to the diversified ownership and volume of trading, the market does not have major, structural vulnerabilities. Therefore, the Commission’s increased enforcement and regulatory actions can reduce the number of bad actors in a basically sound market.”

CCN earlier reported about VanEck’s interest in launching a bitcoin ETF and the SEC’s subsequent hesitance on the issue, as well as the agency’s decision to deny the Winklevoss twins’ latest bid to create a cryptocurrency ETF.

To read the letter in full, click here.

Images from Shutterstock

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Published at Mon, 30 Jul 2018 00:00:56 +0000

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Introducing a Programming Language so Simple, It “Fits on a T-shirt”

http://plas2017.cse.buffalo.edu/

Blockstream is introducing Simplicity, a new programming language for blockchain-based smart contracts, intended for inclusion in Blockstream’s sidechains and eventually in bitcoin. The new language was presented by its creator, Russell O’Connor, Infrastructure Tech Developer at Blockstream, at the ACM SIGSAC Workshop on Programming Languages and Analysis for Security (PLAS 2017).

“Simplicity is a blockchain programming language that is so simple, it fits on a t-shirt,” O’Connor told bitcoin Magazine. “It is critical that smart contracts behave in ways that all participants expect, and applying formal verification to Simplicity allows us to achieve that.”

Simplicity is still a Blockstream Research & Development project, but there’s potential for its use in Blockstream products in the future, according to the company’s announcement.

“Simplicity is flexible enough that I anticipate many new, domain-specific, languages will generate Simplicity, and this will give users the freedom to generate smart contracts using the tools that most suit their needs,” added O’Connor.

O’Connor’s paper, titled “Simplicity: A New Language for Blockchains,” presents Simplicity as “a new programming language, designed to be used for cryptocurrencies and blockchain applications, which aims to improve upon existing cryptocurrency languages, such as bitcoin Script and Ethereum’s EVM [virtual machine], while avoiding some of the problems they face.”

bitcoin script is limited by design and unsuitable for complex smart contracts that need more than a small set of simple templates to perform tasks like digital signature verification. Ethereum, on the other hand, includes a more expressive and flexible, Turing-complete programming language, which allows for arbitrarily complex smart-contracts in principle.

But, in practice, Ethereum doesn’t support static analysis to pre-determine the computing resources that a program will require and, thus, filter out too costly contracts and infinite loops. Therefore, pre-paid “gas” fees are lost when an Ethereum program “runs out of gas.” The simpler bitcoin scripting, which supports static analysis, doesn’t present similar issues.

In a post to the bitcoin-dev mailing list, O’Connor proposed Simplicity as an alternative to bitcoin Script, noting that static analysis is important for both node operators and for Simplicity program designers.

“Static analysis is a technique that provides a universal algorithm to determine how much any Simplicity program will cost to run before you stake your money on it,” O’Connor told bitcoin Magazine.

Simplicity can be seen as a more flexible alternative to bitcoin scripting, not Turing-complete but expressive enough to build useful smart contracts for blockchain applications, or as an alternative to Ethereum, which will support static analysis and other desirable features including improved safety, formal semantics, and Merkelized Abstract Syntax Trees (MASTs).

While Simplicity is intended as a low-level language for smart contracts, O’Connor envisages the possibility of compiling programs written in higher-level languages (like Ethereum’s Solidity) to Simplicity.

“Ivy and the Σ-State Authentication Language are existing programming language development efforts that may be suitable for being compiled to Simplicity,” notes O’Connor in the paper. “For the time being, generating Simplicity with our [Haskell] and [Coq] libraries is possible.”

The next step in Simplicity’s development will be a bare-bones SDK (Software Developer Kit) that will include formal semantics and correctness proofs in Coq, a Haskell implementation for constructing Simplicity programs and a C interpreter for Simplicity. Then, the new language will be ready for initial deployment in the Elements project, Blockstream’s open-source codebase for sidechains, so that developers can start experimenting with the code.

But, as O’Connor stated on bitcoin-dev, “Only after extensive vetting would it be suitable to consider Simplicity for inclusion in bitcoin.”

The post Introducing a Programming Language so Simple, It “Fits on a T-shirt” appeared first on Bitcoin Magazine.

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