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[...]it would mitigate cybersecurity and other risks attendant with investor blockchain private key security through ETP institutionalization of cybersecurity measures and insurance coverage of ETP assets. [...]a vehicle like GBTC is said to have a "spot" exposure to the cryptocurrency commodity9 An investment vehicle's spot exposure to a commodity (for example, where a grantor trust vehicle like GBTC directly holds only Bitcoin) represents neither a commodity future subject to regulation by the CFTC nor a security that would subject the vehicle to regulation under the Investment Company Act of 1940 (the 1940 Act).10 Nevertheless, if GBTC were to offer and sell its shares publicly as an ETP without any restrictions, GBTC's offering would be governed by the Securities Act (and potentially state securities registration laws). [...]offerings could only be made pursuant to a registration statement declared "effective" by the SEC. Because of GBTC's regulatory posture, Grayscale's registration statement for GBTC, unlike sponsors of many other ETP products, did not involve public notice or public comment. In each case, authorized participant activity generally continues until market prices and expected NAV reach equilibrium. Because the arbitrage mechanism depends on market participants' expectation of the ETP's NAV, authorized participants' arbitrage share creation and redemption activity depends on the transparency of the value of the ETP's underlying portfolio assets to all market participants at the time that NAV is struck.