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Consensys Urges SEC to Recognize Ethereum’s Advanced Safeguards in Comment Letter on ETH ETF Approval

April 1, 2024
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Consensys has submitted a comment letter to the U.S. Securities and Exchange Commission (SEC) advocating for the approval of Ethereum-based exchange-traded funds (ETFs). I

In a recent request for public comments on Nasdaq’s application for a rule change to permit the trading of iShares Ethereum Trust, the SEC specifically inquired about unique concerns related to ether’s proof of stake consensus mechanism and concentration of control or influence. Consensys responded to these concerns by explaining that Ethereum’s PoS model incorporates robust anti-fraud and anti-manipulation mechanisms.

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One of the key advantages highlighted by Consensys is faster block finality. With Ethereum’s transition to PoS, transaction finality is achieved within a shorter timeframe, making it more secure against potential attacks. The company also emphasizes the distributed and randomized validation process employed in Ethereum PoS, which prevents large stakeholder control and serves as a check against manipulation.

Consensys further addresses the concept of Byzantine fault tolerance (BFT), which measures the minimum proportion of network validators required for system integrity. Researchers have found that Ethereum’s BFT cost to attack the network is significantly higher than Bitcoin’s, reducing the likelihood of network compromise. Additionally, Ethereum’s PoS model includes slashing penalties for validators who violate protocol rules, acting as both a deterrent and a punitive measure.

The comment letter emphasizes the environmental benefits of Ethereum’s PoS model compared to Bitcoin’s PoW. With significantly lower energy consumption, Ethereum demonstrates its commitment to sustainability.

Consensys highlights the decentralized community and transparency of Ethereum as additional safeguards. The active and sizable developer community, combined with public development work, makes Ethereum more resistant to attacks and enables comprehensive monitoring of network activities.

In conclusion, Consensys urges the SEC to recognize the advanced safeguards inherent in Ethereum’s design. The company asserts that Ethereum’s PoS implementation meets and exceeds the exemplary security and resilience safeguards underlying Bitcoin-based ETPs that have previously been approved by the SEC. Consensys considers its comment letter to be a step towards driving progress and providing relevant and useful information to the public. The company looks forward to an ongoing, constructive dialogue with the SEC and its staff.

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