Ben Strack

Casey Wagner

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Welcome to the On the Margin Newsletter, brought to you by Ben Strack and Casey Wagner. Here’s what you’ll find in today’s edition:



<ul class="wp-block-list">
<li>Takeaways from the first month of trading for US spot ETH ETFs.</li>



<li>Fed Chair Jerome Powell spoke. Casey translates. </li>



<li>The mixed economic data you might have missed this week.</li>
</ul>



<h2 class="wp-block-heading">One month in the books for US spot ETH ETFs</h2>



Spot ether ETFs hit the US market one month ago today, and the category’s net flows remain in the red. But perhaps that’s not the whole story.



Thursday’s market close marked 23 trading days in the books for these funds. Some notable stats during that span (courtesy of Farside Investors <a href="https://farside.co.uk/ethereum-etf-flow-all-data/">data</a>) include:



<ul class="wp-block-list">
<li>Days of net inflows: 8</li>



<li>Days of net outflows: 15</li>



<li>Total flows: -$459 million</li>



<li>Highest inflows: iShares Ethereum Trust (ETHA), +$1 billion</li>



<li>Highest outflows: Grayscale Ethereum Trust (ETHE), -$2.5 billion</li>
</ul>



Let’s compare those with <a href="https://farside.co.uk/bitcoin-etf-flow-all-data/">figures</a> from the first 23 trading days for US spot bitcoin ETFs:



<ul class="wp-block-list">
<li>Days of net inflows: 17</li>



<li>Days of net outflows: 6</li>



<li>Total flows: +$3.9 billion</li>



<li>Highest inflows: iShares Bitcoin Trust (IBIT), +$4.6 billion</li>



<li>Highest outflows: Grayscale Bitcoin Trust (GBTC), -$6.55 billion</li>
</ul>



I know, I know. BTC and ETH aren’t the same. It’s unfair to compare these ETF categories. Yada yada yada.



Bitwise&#8217;s Head of Research, Ryan Rasmussen, alluded to this in his remarks to me, describing the traction for the ether funds as &#8220;phenomenal&#8221; so far.



“Is it as strong as bitcoin? No,” he acknowledged. “But we never expected it to be.”



In fact, various segment observers have said they ultimately expect US spot ETH ETFs to see roughly a third of the inflows that bitcoin funds have seen ($17.6 billion so far, in seven and a half months). We will need more time to see if that plays out.



Beyond ETHE, the rest of the ether ETF segment has reeled in more than $2 billion — with BlackRock’s ETHA hitting the $1 billion net inflow milestone this week.&nbsp;



Trailing behind that fund are the Fidelity Ethereum Fund (FETH) and the Bitwise Ethereum ETF (ETHW), with positive flows amounting to $390 million and $311 million, respectively.



There was also strong <a href="https://x.com/EricBalchunas/status/1815879736217784441">trading volume</a> out of the gate, Bloomberg Intelligence data showed — with the day-one volumes for ETHA and FETH beating all other recent ETF launches (when excluding the BTC funds).



Still, the narrative around bitcoin is simpler than that of ETH, 21Shares exec Federico Brokate previously <a href="https://blockworks.co/news/21shares-us-crypto-etf-adoption-outlook">told Blockworks</a> — meaning investors (particularly institutions and advisers) are still learning about the latter asset.&nbsp;



Rasmussen’s colleague, Bitwise CIO Matt Hougan, <a href="https://blockworks.co/news/ether-etf-approval-unlikely-soon">warned</a> during a March panel at Blockworks’ Digital Asset Summit that Wall Street/TradFi was still digesting BTC and may need more time than May (when the SEC approved the ether funds) before jumping into ETH.



Rasmussen said the second-largest crypto asset by market cap came up in each of his recent meetings with 15 different advisers around the Pacific Northwest.&nbsp;&nbsp;&nbsp;



“They were shocked and fascinated to learn that Ethereum is a technology platform that generates cash flow and pays out a dividend-like yield to stakers,” he said. “To traditional investors, that looks and sounds just like a tech stock.”



It’s worth noting that ETH is down about 23% over the past month.



Analysts have pointed out potential pro-crypto catalysts in the coming months — such as&nbsp; potential post-election regulatory clarity and lower interest rates — that may boost ETH ETF flows.



However, the outflow of assets from Grayscale’s ETHE will likely need to stop before the category&#8217;s collective net flows see a sizable boost. While that product&#8217;s net outflows paused for a day on Aug. 12, they have resumed in each of the eight trading days since.



Rasmussen noted: “While the journey to Ethereum is slower than we in the industry would like, it&#8217;s already begun.”



Let’s see where we are in another month and go from there.&nbsp;



— Ben Strack



<h2 class="wp-block-heading">$2,811&nbsp;</h2>



The previous support level for ETH, which is now acting as “resistance,” according to a report published this week by crypto exchange Kraken.&nbsp;



ETH’s bounce-back from its low of $1,911 on Aug. 5 has been less pronounced than BTC’s retracement since hitting $49,111 that day.&nbsp;



The trendline on the relative strength index (RSI) originating from the $4,090 high ETH hit on March 12 remains intact. If ETH can’t eclipse the $2,811 resistance mark on a daily closing basis, “it could face further downside pressure, potentially retesting recent lows or even moving lower,” the Kraken report notes.&nbsp;



ETH’s price was $2,730 at 2 pm ET Friday — a 4.5% rise from 24 hours prior.



<h2 class="wp-block-heading">J. Powell at J. Hole</h2>



Fed Chair Jerome Powell, as expected, clearly signaled the central bank would cut interest rates at its next policy-setting meeting in September.&nbsp;



He did not give any indication as to the size of the cut, but he assured markets the Fed is committed to preventing additional weakening in the labor market.&nbsp;



“The time has come for policy to adjust,” Powell said during a keynote address at the Kansas City Fed’s annual conference in Jackson Hole. “The direction of travel is clear, and the timing and pace of rate cuts will depend on incoming data, the evolving outlook, and the balance of risks.”



Equities immediately reacted well to Powell’s comments, which were largely anticipated. The Dow Jones Industrial Average gained as much as 1% in the half hour after Powell took the podium, while the S&amp;P 500 and Nasdaq Composite indexes gained 0.7% and 0.9%, respectively.&nbsp;



Bitcoin rallied as much as 2.2% before 11 am ET before paring gains, according to data from Coinbase.&nbsp;



Powell reiterated that central bankers “do not seek or welcome further cooling in labor market conditions” and will therefore act accordingly by lowering interest rates in September. He expressed confidence that labor market strength could be maintained with “dialing back of policy restraint.”



“It seems unlikely that the labor market will be a source of elevated inflationary pressures anytime soon,” he added.&nbsp;



I’d say we are officially in pivot territory. It wasn’t that long ago that Powell seemed just fine with lowering inflation — even if that came at the cost of slowing economic growth.&nbsp;



Today, though, he was extremely clear that central bankers will prioritize labor market health. Hello, dovish Powell!



— Casey Wagner



<h2 class="wp-block-heading">Did You Notice</h2>



Happy Friday! After relatively mixed data in recent days, stocks were poised to close the week in the green. Here’s a recap of the latest economic developments:&nbsp;



<ul class="wp-block-list">
<li>The Bureau of Labor Statistics on Wednesday released preliminary data suggesting the economy added 818,000 fewer jobs in the 12 months ended March 2024 than were initially reported. This is almost 30% lower than originally relayed and the largest revision since 2009. The fear here is that the labor market is not as healthy as markets initially thought. But Powell insisted on Friday that central bankers do not believe “the labor market will be a source of elevated inflationary pressures anytime soon.”</li>



<li>On the flip side, initial jobless claims barely rose last week, according to data released Thursday. Markets reacted well to the positive report, which showed initial claims increased by 4,000 the week ended Aug. 17. The four-week moving average is now at its lowest point in a month. </li>



<li>Another potentially troublesome data point this week was the Flash Composite PMI for August, released on Thursday. The report showed the US S&amp;P Global Composite PMI edged lower to 54.1 — above the expected 53.5. Services PMI moved higher, however, coming in at 55.2 in August after reading 55 in July. </li>
</ul>



— Casey Wagner



<h2 class="wp-block-heading">Bulletin Board</h2>



<ul class="wp-block-list">
<li>After bitcoin’s surge above $62,000 Friday morning and subsequent drop, BTC had risen back up above $63,100 by 2 pm ET — up 4.6% from a day ago.</li>



<li>In case you missed it, an adviser for Kamala Harris’s campaign (when asked about crypto) <a href="https://www.bloomberg.com/news/articles/2024-08-21/harris-supports-policies-to-expand-crypto-industry-aide-says?srnd=phx-crypto">told Bloomberg News</a>: “She’s going to support policies that ensure that emerging technologies and that sort of industry can continue to grow.” This is a step toward the type of rhetoric Exodus legal chief Veronica McGregor <a href="https://blockworks.co/news/kamala-harris-crypto-policy-reset-outlook">told Blockworks</a> she was hoping to hear from Harris and her team.</li>



<li>Also earlier this week at the Wyoming Blockchain Symposium, Sen. Tim Scott, R-S.C., signaled he <a href="https://www.coindesk.com/policy/2024/08/21/top-republican-retains-hope-us-crypto-legislation-can-get-done-this-year/?utm_medium=social&amp;utm_source=twitter&amp;utm_campaign=coindesk_main&amp;utm_content=editorial&amp;utm_term=organic">would consider</a> creating a crypto-focused subcommittee if he becomes chair of the Senate Banking Committee.  </li>
</ul>



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One month in the books for US spot ETH ETFs

Katherine Ross

The Securities and Exchange Commission delayed a decision on BlackRock’s proposed spot ether ETF.&nbsp;



The delay pushes any decision on the proposed fund to March 10, according to an official release by the agency.&nbsp;



The delay was largely expected, with the SEC also delaying decisions on Fidelity’s proposed fund on Jan. 18.&nbsp;



Read more: <a href="https://blockworks.co/news/bitcoin-etfs-approved-ether-funds-next">After spot bitcoin ETF approval, eyes shift to ether fund decision</a>



“Spot Ethereum ETF Delays will continue to happen sporadically over the next few months. Next date that matters is May 23rd,” Bloomberg Intelligence analyst James Seyffart said.



<figure class="wp-block-embed is-type-rich is-provider-twitter wp-block-embed-twitter"><div class="wp-block-embed__wrapper">
<blockquote class="twitter-tweet" data-width="550" data-dnt="true">Spot Ethereum ETF Delays will continue to happen sporadically over the next few months. Next date that matters is May 23rd <a href="https://t.co/2zBBvHkrVk">https://t.co/2zBBvHkrVk</a>&mdash; James Seyffart (@JSeyff) <a href="https://twitter.com/JSeyff/status/1750247415137833151?ref_src=twsrc%5Etfw">January 24, 2024</a></blockquote><script async src="https://platform.twitter.com/widgets.js" charset="utf-8"></script>
</div></figure>



The decision comes just weeks after the SEC <a href="https://blockworks.co/news/bitcoin-etf-race-recap">approved nearly a dozen spot bitcoin ETFs</a>. Three commissioners — Hester Peirce, Mark Uyeda and Chair Gary Gensler — voted in favor of the ETFs.&nbsp;



Following <a href="https://blockworks.co/news/sec-grayscale-spot-bitcoin-etf">Grayscale&#8217;s legal victory in August,</a> the SEC was compelled to reevaluate its application for a spot bitcoin ETF conversion. Despite this progress, the status of ether ETFs continues to be unclear.



In an interview on Tuesday, <a href="https://blockworks.co/news/hester-peirce-ether-etf-precedent">Peirce said that the SEC</a> would “apply precedent” to any decisions on spot ether ETFs. She further noted that the agency doesn’t plan to repeat history and face another court case in order to approve such funds.&nbsp;



“I’m not holding my breath,” Lara Crigger, editor-in-chief at VettaFi previously told Blockworks about ether ETF approval.&nbsp;



However, Seyffart previously said that he was more bullish about the future of ether ETFs.&nbsp;



“If [Gensler] goes after ETH, it’s not just going to be a lot of these industry players; it will also be the CFTC that he has to contend with, and it’s just not worth it,” he told On the Margin podcast.The delay was largely expected after the SEC also delayed Fidelity’s proposal



In his press release following <a href="https://blockworks.co/news/commissioner-etf-statements-signals-contention">bitcoin ETF approvals</a>, Gensler noted that the decision “should in no way signal the Commission’s willingness to approve listing standards for crypto asset securities.”



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</ul>

BlackRock

BlackRock spot ether ETF decision delayed by SEC

Securities and Exchange Commission Commissioner Hester Peirce believes that spot ether ETFs won’t need a court battle to get an approval.



When asked by Coinage Media if the SEC will hold off on approving spot bitcoin ETFs until a court case is pushed through the legal system, Peirce said, “that’s not how we’re going to do our approvals.”



“We need to just be applying regular [consideration] to these products. The same kind of consideration that we apply to similar products and, so, we shouldn’t need a court to tell us that our approach is arbitrary and capricious in order for us to get it right,” she said.&nbsp;



Read more: <a href="https://blockworks.co/news/commissioner-etf-statements-signals-contention">Commissioner statements on bitcoin ETF approvals signal contention among SEC leaders</a>



Her comments come just weeks after the SEC formally approved nearly a dozen spot bitcoin ETFs. While the move wasn’t a total surprise to some — between an attacker seizing the <a href="https://blockworks.co/news/sec-posts-retracts-bitcoin-etf-order">SEC’s X account to make a false pos</a>t claiming that the agency issued approvals and the aforementioned <a href="https://blockworks.co/news/grayscale-sec-spot-bitcoin-etf#">Grayscale court ruling </a>— it left the fate of the spot ether ETFs in the air.&nbsp;



BlackRock, Ark 21Shares and Grayscale have thrown their hats in the ring for a spot ether ETF. Grayscale, similarly to what happened with its spot bitcoin ETF, is trying to convert its Ethereum Trust into an ETF.



However, SEC Chair <a href="https://blockworks.co/tag/gary-gensler">Gary Gensler</a>, in his statement about spot bitcoin ETF approvals, didn’t seem so sold on further approvals.



Read more: <a href="https://blockworks.co/news/sec-wrong-bitcoin-etf-elizabeth-warren">Senator Warren: SEC is &#8216;wrong on the law&#8217; approving bitcoin ETFs</a>



“Importantly, today’s commission action is cabined to ETPs holding one non-security commodity, bitcoin,” Gensler said. “It should in no way signal the Commission’s willingness to approve listing standards for crypto asset securities.”



Peirce, however, said, “We squandered a decade of opportunities to do our job. If we had applied the standard we use for other commodity-based ETPs, we could have approved these products years ago, but we refused to do so until a court called our bluff.”



Peirce is known for being <a href="https://blockworks.co/news/hester-peirce-sec-endgame">outspoken when it comes to her thoughts</a> on the SEC’s approach to crypto. When it comes to the agency’s approach to regulation through enforcement, she once said, “there doesn’t seem to be a rhyme or reason for a lot of cases we bring.”



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bitcoin etf

SEC will ‘apply precedent’ when making decision on spot ether ETFs: Peirce

Update: BlackRock Thursday afternoon submitted a 19b-4 filing with Nasdaq, which is an SEC form to record rule changes. The filing noted that BlackRock intends to list and trade shares of the iShares Ethereum Trust on the Nasdaq exchange.



<hr class="wp-block-separator has-alpha-channel-opacity"/>



BlackRock could jump into the race for a spot ether ETF soon after the asset management giant proposed a bitcoin fund in June, a Thursday disclosure suggests.  



A filing for an iShares Ethereum Trust appeared on the website for Delaware’s department of state Thursday.&nbsp;



<figure class="wp-block-image size-large is-resized"><img loading="lazy" decoding="async" width="1202" height="886" src="https://blockworks-co.imgix.net/wp-content/uploads/2023/11/Delaware-filing-ETH-ETF-blackrock.jpg?w=1024&amp;h=1024" alt="" class="wp-image-73352" style="aspect-ratio:1.3562913907284768;width:641px;height:auto" srcset="https://blockworks-co.imgix.net/wp-content/uploads/2023/11/Delaware-filing-ETH-ETF-blackrock.jpg?w=1202 1202w, https://blockworks-co.imgix.net/wp-content/uploads/2023/11/Delaware-filing-ETH-ETF-blackrock.jpg?w=300 300w, https://blockworks-co.imgix.net/wp-content/uploads/2023/11/Delaware-filing-ETH-ETF-blackrock.jpg?w=1024 1024w, https://blockworks-co.imgix.net/wp-content/uploads/2023/11/Delaware-filing-ETH-ETF-blackrock.jpg?w=768 768w, https://blockworks-co.imgix.net/wp-content/uploads/2023/11/Delaware-filing-ETH-ETF-blackrock.jpg?w=349 349w, https://blockworks-co.imgix.net/wp-content/uploads/2023/11/Delaware-filing-ETH-ETF-blackrock.jpg?w=354 354w, https://blockworks-co.imgix.net/wp-content/uploads/2023/11/Delaware-filing-ETH-ETF-blackrock.jpg?w=297 297w, https://blockworks-co.imgix.net/wp-content/uploads/2023/11/Delaware-filing-ETH-ETF-blackrock.jpg?w=80 80w" sizes="auto, (max-width: 1202px) 100vw, 1202px" /></figure>



The filing could signal the finance giant, which manages about $9 trillion in assets, plans to propose such an offering to the US Securities and Exchange Commission. It appears no formal proposal has been made to the regulator.&nbsp;



<figure class="wp-block-embed is-type-rich is-provider-twitter wp-block-embed-twitter"><div class="wp-block-embed__wrapper">
<blockquote class="twitter-tweet" data-width="550" data-dnt="true">Multiple people asking &quot;is this real&quot; &#8212; yes its real. An entity with this name was indeed registered in Delaware. That&#39;s all we can really confirm at this time. Those images are real and from the State of Delaware website.&mdash; James Seyffart (@JSeyff) <a href="https://twitter.com/JSeyff/status/1722636312274993531?ref_src=twsrc%5Etfw">November 9, 2023</a></blockquote><script async src="https://platform.twitter.com/widgets.js" charset="utf-8"></script>
</div></figure>



A BlackRock spokesperson declined to comment.&nbsp;



<a href="https://blockworks.co/tag/blackrock">BlackRock</a> filed with the SEC to launch a spot bitcoin ETF on June 15. A disclosure for that planned iShares Bitcoin Trust, however, had appeared on Delaware’s website on June 8.



Ether’s price was at about $2,030 at 10:30 am ET — up more than 8% in the last 24 hours.&nbsp;



Read more: <a href="https://blockworks.co/news/ether-etfs-proshares-sec">Another ether ETF launches — where do the rest stand?</a>



BlackRock would join several other issuers seeking to offer an ETF that holds ETH directly, including <a href="https://blockworks.co/news/21shares-ark-filing-for-spot-ether-etf">Ark Invest and 21Shares</a>, as well as VanEck.&nbsp;&nbsp;



<a href="https://blockworks.co/news/grayscale-eth-trust-ethe-filing-vaneck-proshares">Grayscale Investments moved on Oct. 2</a> to convert its Ethereum Trust into a spot ether fund. &nbsp; Hashdex and Invesco also have filings in front of the SEC to launch spot ether products.



Updated Nov. 9, 2023 at 10:50 am ET: Modified for additional context. 



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BlackRock appears set to propose a spot ether ETF

On this episode of Blockworks&#8217; podcast &#8220;<a href="https://youtu.be/1j5mDQnA4i4" target="_blank" rel="noreferrer noopener">On the </a><a href="https://youtu.be/8Tp8yZQy8Oo" target="_blank" rel="noreferrer noopener">Margin</a>,&#8221; Michael Ippolito, co-founder, is joined by Mike McGlone, the Senior Commodity Strategist at Bloomberg Intelligence. 



Mike shares his thoughts on the Bitcoin futures ETFs, the outlook for an Ethereum ETF, crypto market cycles, and the incoming Bitcoin supercycle.



They also covered: 



<ul class="wp-block-list"><li>China&#8217;s effect on commodity prices</li><li>The deflationary forces of technology</li><li>and more!</li></ul>



Watch the full episode down below! 👇



<figure class="wp-block-embed is-type-video is-provider-youtube wp-block-embed-youtube wp-embed-aspect-16-9 wp-has-aspect-ratio"><div class="wp-block-embed__wrapper">
<iframe loading="lazy" title="Bloomberg Analyst: The Bitcoin Supercycle Is Here | Mike McGlone" width="1024" height="576" src="https://www.youtube.com/embed/8Tp8yZQy8Oo?feature=oembed" frameborder="0" allow="accelerometer; autoplay; clipboard-write; encrypted-media; gyroscope; picture-in-picture" allowfullscreen></iframe>
</div></figure>



&#8220;On the Margin&#8221; is a two-part show.&nbsp;Once a week, Mike interviews industry experts, and then at the end of the week he is joined by a co-host where they break down the top crypto and macro stories. Episodes go live every Wednesday and Saturday morning.



Subscribe to &#8220;On the Margin&#8221; today on <a href="https://podcasts.apple.com/us/podcast/lyn-alden-explains-connection-between-inflation-bitcoin/id1558223079?i=1000513411286" target="_blank" rel="noreferrer noopener">Apple</a> or <a href="https://spoti.fi/3bTa9uw" target="_blank" rel="noreferrer noopener">Spotify</a>, or watch episodes on <a href="https://youtube.com/playlist?list=PLvER9nHSRN3xVs_p-dl7L7K_ZgL6lSudu" target="_blank" rel="noreferrer noopener">YouTube</a>.



Are you a UK or EU reader that can&#8217;t get enough investor-focused content on digital assets? <a target="_blank" href="https://cms.blockworks.co/events/das-london/" rel="noreferrer noopener">Join us</a>&nbsp;in London on November 15th and 16th for the Digital Asset Summit (DAS) London. Use code ARTICLE for £75 off your ticket.&nbsp;<a target="_blank" href="https://cms.blockworks.co/events/das-london/" rel="noreferrer noopener">Buy it now</a>.

Bitcoin

Podcast: Bloomberg Analyst: The Bitcoin Supercycle Is Here | Mike McGlone

<div id="highlights-block_611586197fe21" class="highlights">
 <ul>
 <li>Kryptoin’s ETF will hold Ethereum and value its shares daily as determined by the CF Ether-Dollar US Settlement Price</li>
 <li>Filing comes nearly two years after the Delaware-based firm filed to launch a bitcoin ETF in October 2019</li>
 </ul>
 
</div>



Kryptoin is looking to launch an Ethereum ETF several months after joining the swathe of issuers seeking to bring to market an <a href="https://cms.blockworks.co/ontario-securities-regulator-approves-first-bitcoin-etf/">ETF that would hold bitcoin.</a>&nbsp;



The Delaware-based firm’s proposed Kryptoin Ethereum ETF Trust will hold Ethereum and value its shares daily as determined by the CF Ether-Dollar US Settlement Price, according to a disclosure <a href="https://www.sec.gov/Archives/edgar/data/1877610/000157587221000189/es004_s1.htm">filed with the SEC on Thursday</a>. This price is an independently calculated value based on an aggregation of executed trade flow of major ETH spot exchanges, the document notes.



“The trust provides investors with the opportunity to access the market for Ether through a traditional brokerage account without the potential barriers to entry or risks involved with holding Ether directly, acquiring it from an online exchange platform, or mining it, as referenced above,” the filing states.



The ETF does not plan to purchase or sell Ether directly. Rather, when it sells or redeems its shares, it will do so in “in-kind” transactions in blocks of 100,000 shares at the trust’s net asset value, the disclosure notes. Authorized participants will deliver Ether to the trust in exchange for shares when they purchase shares, and the trust will deliver Ether to such authorized participants when they redeem shares.



Authorized participants may then offer shares to the public at prices that depend on the supply and demand for shares, the value of the trust’s assets, and market conditions, the filing adds.



Kryptoin is the third issuer to file for an Ethereum ETF this year, James Seyffart, an ETF analyst at Bloomberg Intelligence, said in a Twitter post. So far in 2021, he added, there have been 21 crypto ETF filings.&nbsp;



VanEck was the first fund manager <a href="https://www.sec.gov/Archives/edgar/data/1860788/000093041321001047/c101690_s1.htm">to apply</a> for an Ethereum Trust in May, and WisdomTree Investments followed that up with <a href="https://www.sec.gov/Archives/edgar/data/0001864519/000119312521175426/d153307ds1.htm">a filing of its own</a> later that month.



Kryptoin first filed for a bitcoin ETF in 2019, and made amendments to the filing in April 2021 to include the service providers that would assist in launching, including Gemini Custody, BNY Mellon, Foreside, and CF Benchmarks. The SEC had <a href="https://kryptoin.io/sec-delays-kryptoin-bitcoin-etf-filing-decision-to-july-27/">pushed back its decision</a> on the ETF to July 27, but appears to still be evaluating this product.&nbsp;&nbsp;



The firm did not immediately respond to a request for further comment about the proposed products.



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