Comment Text:
BitPay is the leading merchant acquirer for bitcoin, and has been around since May 2011. We help major companies such as Microsoft and Newegg accept bitcoin payments. BitPay is headquartered in Atlanta and registered with FinCEN as a Money Services Business.
During our normal course of business, BitPay holds bitcoins as an asset. We functionally use bitcoin to pay many of our employees and vendors worldwide. BitPay has a need for derivatives around bitcoin (puts and calls) that can hedge against the volatility of the underlying bitcoin price.
We have spent much time with the team from LedgerX and found them to be extremely knowledgeable and capable of building a reliable and transparent market for bitcoin options. We hope the CFTC will approve LedgerX to clear asset-settled bitcoin derivatives contracts. These asset-settled options will help reduce volatility risk in our business, as we are holding the underlying bitcoin asset.
BitPay also believes that it is important for the United States to take a leadership position in the liquidity and trading of bitcoin and bitcoin derivatives. Bitcoin by its nature is global, and can be used anywhere in the world where there is internet access. In the 1990s the United States took an early leadership position in internet access and availability. We believe the CFTC should provide regulatory oversight, encourage transparency, and allow the creation of a robust derivatives market for bitcoin.
