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institutional-adoption-etfs-banks-and-treasuries
Blog

The Hidden Cost of ETF Authorized Participant Privilege

Bitcoin's ETF victory created a new, centralized bottleneck. The oligopoly of Authorized Participants (APs) extracts hidden rents and introduces systemic fragility, undermining the very decentralization the asset class champions.

introduction
THE GATEKEEPER TAX

Introduction

The ETF's operational design creates a centralized bottleneck that extracts value from the underlying crypto ecosystem.

Authorized Participant (AP) privilege creates a structural rent. A handful of traditional finance giants control the creation and redemption of ETF shares, acting as the sole gateway between the fund and the underlying Bitcoin. This bottleneck allows them to capture arbitrage profits that, in a native crypto system, would accrue to a decentralized network of validators or liquidity providers.

The cost is a hidden tax on every ETF investor. The AP's profit margin is embedded in the fund's tracking error and expense ratio, a fee layer that protocols like Lido or Rocket Pool eliminate through permissionless node operation. This centralization reintroduces the very intermediary costs that Bitcoin's peer-to-peer design was built to destroy.

Evidence: BlackRock's iShares Bitcoin Trust (IBIT) reported an expense ratio of 0.25%, a direct cost that does not exist for a self-custodied Bitcoin holder. This fee funds the AP's operational monopoly, contrasting with the sub-0.1% execution fees achievable on decentralized exchanges like Uniswap or CowSwap.

key-insights
THE AP ARBITRAGE

Executive Summary

Bitcoin ETF approval created a new, centralized bottleneck that extracts billions from the crypto ecosystem.

01

The Problem: The AP Cartel

A handful of ~10 Authorized Participants (APs) like JPMorgan and Goldman Sachs have exclusive rights to create/destroy ETF shares. This creates a multi-billion dollar arbitrage moat and centralizes price discovery away from on-chain markets.

  • Extracts ~$2-3B/year in arbitrage profits from retail flows.
  • Creates systemic fragility by concentrating power in legacy finance entities.
  • Slows innovation by walling off capital from native DeFi primitives.
~10
Entities
$2-3B
Annual Extract
02

The Solution: On-Chain Creation/Redemption

Protocols like Babylon and Stroom are building trust-minimized, permissionless systems for Bitcoin staking and liquidity. The endgame is direct, programmatic ETF share minting via smart contracts.

  • Disintermediates the APs, returning arbitrage profits to stakers/LPs.
  • Unlocks Bitcoin yield for DeFi (lending, collateral) without custodial wrappers.
  • Creates a native settlement layer for capital flows between TradFi and DeFi.
Permissionless
Access
Native Yield
Unlocked
03

The Catalyst: Regulatory Inevitability

The SEC's ETF approval sets a legal precedent for digital asset securities. The next logical step is on-chain compliance via protocols like Polygon's Chain Abstraction or Avail's data availability, forcing AP infrastructure onto public rails.

  • Forces transparency via immutable, auditable creation/redemption logs.
  • Reduces settlement risk from T+2 to near-instant finality.
  • Opens the door for 24/7 ETF trading settled on-chain, bypassing market hours.
T+2 → ~0
Settlement
24/7
Markets
thesis-statement
THE STRUCTURAL FLAW

The Central Thesis

The ETF settlement mechanism creates a privileged, non-competitive access point that undermines the core permissionless and censorship-resistant properties of Bitcoin.

ETF settlement is a permissioned gateway. Authorized Participants (APs) like JPMorgan and Goldman Sachs are the sole entities permitted to create and redeem ETF shares. This creates a centralized bottleneck for capital flows, contradicting Bitcoin's foundational ethos of open, peer-to-peer access.

The AP privilege extracts economic rent. This exclusive role allows APs to capture the arbitrage spread between the ETF's NAV and its market price. This is a hidden tax on investors, a cost that does not exist in the direct, on-chain ownership model.

This model mirrors TradFi's broken plumbing. The AP system is a direct import from traditional ETF mechanics, replicating the opaque intermediation that crypto rails like Uniswap and direct Lightning payments were built to dismantle.

Evidence: The Grayscale Bitcoin Trust (GBTC) historically traded at a persistent premium or discount to NAV, demonstrating the inefficiency and rent extraction inherent in a closed creation/redemption model before its ETF conversion.

market-context
THE HIDDEN COST

The Current Oligopoly

The ETF settlement process creates a structural advantage for a handful of privileged banks, mirroring the centralization risks seen in early blockchain bridges.

Authorized Participants (APs) control liquidity. The ETF creation/redemption mechanism is gated by a select group of global banks like JPMorgan and Goldman Sachs. This centralizes the critical on/off-ramp between the ETF's shares and the underlying Bitcoin, creating a single point of failure and rent extraction.

This mirrors pre-intent bridge architecture. Early cross-chain bridges like Multichain and early Stargate operated as centralized, trusted mints, creating systemic risk. The AP model is the TradFi equivalent—a permissioned, opaque liquidity layer vulnerable to manipulation and censorship.

The cost is paid in slippage and latency. Retail and institutional traders outside the AP cartel face wider bid-ask spreads and slower arbitrage execution. This inefficiency is a direct tax, similar to the premium users paid to centralized bridge operators before permissionless solutions like Across and LayerZero emerged.

Evidence: The GBTC arbitrage window. Historical data shows persistent premiums/discounts to NAV that took days to correct, a lag directly attributable to the friction and exclusivity of the AP mechanism. A truly efficient, permissionless system would close these gaps near-instantly.

ETF CREATION/REDEMPTION MECHANICS

The AP Power Matrix: Who Controls the Spigot?

Comparing the control and cost dynamics of Authorized Participant (AP) operations across different Bitcoin ETF structures.

Key Control MetricTraditional ETF (e.g., GBTC)In-Kind Physical ETF (e.g., IBIT, FBTC)Cash-Create ETF (e.g., HODL)

Creation Basket Control

AP + Sponsor (Grayscale)

AP Only

AP Only

Redemption Basket Control

AP + Sponsor (Grayscale)

AP Only

AP Only

Primary Market Fee (Creation)

2.0% (Sponsor Fee)

0.0%

0.0%

Arbitrage Latency Window

1 Day (Private Placement)

< 1 Hour (T+1 Settlement)

< 1 Hour (T+1 Settlement)

AP Capital Requirement

High (Direct BTC Purchase)

Moderate (BTC Custody & Transfer)

Low (Cash Only)

Sponsor 'Spigot' Control

AP Count (Competitive Pressure)

1 (Effectively)

5-7 per fund

5-7 per fund

Primary Market Spread (Typical)

1.5% - 2.5%

0.1% - 0.5%

0.1% - 0.5%

deep-dive
THE AP CARTEL

Anatomy of the Rent Extraction

ETF Authorized Participants (APs) operate a sanctioned oligopoly, extracting value through exclusive arbitrage rights.

APs are a sanctioned oligopoly. The SEC designates a handful of major banks as Authorized Participants, granting them the exclusive right to create and redeem ETF shares. This creates a structural moat that prevents open competition and innovation in the primary market.

The arbitrage mechanism is the rent. APs profit from the spread between the ETF's Net Asset Value (NAV) and its market price. This risk-free arbitrage is a legalized toll on all ETF investors, enforced by the APs' unique creation/redemption privilege.

Crypto's permissionless model is the antithesis. Protocols like Uniswap or Curve Finance allow anyone to act as a liquidity provider and arbitrageur. The automated market maker (AMM) model democratizes the role reserved for TradFi's APs, eliminating the gatekeeper rent.

Evidence: The Bitcoin ETF arbitrage spread, while tight, represents pure economic leakage. In Q1 2024, the average daily spread for major spot Bitcoin ETFs was 5-10 basis points, a multi-million dollar annual revenue stream for APs like Goldman Sachs and JPMorgan.

risk-analysis
THE HIDDEN COST OF ETF AUTHORIZED PARTICIPANT PRIVILEGE

Systemic Risks of the AP Choke Point

Bitcoin ETF flows are gated by a handful of traditional finance giants, creating a single point of failure that contradicts crypto's decentralized ethos.

01

The Custody Bottleneck

All ETF creation/redemption requires physical BTC movement through a single, approved custodian (e.g., Coinbase Custody). This centralizes ~$50B+ in assets under one legal entity, creating a systemic counterparty risk.\n- Single Point of Failure: A regulatory or operational issue at the custodian halts the entire ETF plumbing.\n- Censorship Vector: APs and the custodian act as de facto gatekeepers, able to reject flows.

1
Primary Custodian
~$50B+
Centralized Assets
02

The AP Oligopoly

Only ~5-7 major banks (e.g., Jane Street, JPMorgan, Citadel) act as Authorized Participants. They control all primary market liquidity, extracting rent via arbitrage spreads.\n- Barrier to Entry: High capital and regulatory requirements exclude decentralized players.\n- Spread Capture: APs pocket the delta between NAV and market price, a cost ultimately borne by end investors.

5-7
Dominant APs
10-30 bps
Typical Spread
03

Settlement Latency Risk

The T+2 settlement cycle for AP creations/redemptions is anathema to crypto's finality. It introduces multi-day counterparty and market risk during volatile swings.\n- Capital Inefficiency: APs must post significant collateral for days, limiting market-making capacity.\n- Chain Disconnect: Real-time on-chain activity is mismatched with sluggish traditional settlement, creating arbitrage cliffs.

T+2
Settlement Lag
High
Volatility Risk
04

The On-Chain Disconnect

ETF flows are a synthetic derivative; the underlying BTC is vaulted and inert. This severs the direct economic link between price action and on-chain utility (e.g., DeFi, L2s).\n- Stagnant Coins: ETF BTC doesn't secure the network or participate in the crypto economy.\n- Vulnerability to Rehypothecation: While not currently allowed, the custodial structure opens the door for future fractional reserve practices.

0%
Network Utility
Synthetic
Economic Exposure
05

Regulatory Capture Vector

The AP/Custodian model hands ultimate control to legacy regulators (SEC, Finra). A single rule change can freeze or redirect billions in capital flows without touching the underlying Bitcoin protocol.\n- Policy Risk: Future KYC/AML demands on APs could mandate surveillance on all ETF investors.\n- Kill Switch: Regulators can pressure the few choke-point entities to halt operations, effectively turning off the ETF.

Few
Pressure Points
Total
Regulatory Control
06

The Native Alternative: Trust-Minimized Bridges

Solutions like zk-proof based bridges and light client relays (e.g., proposals for Babylon, Nomic) enable direct, programmable BTC staking and wrapping without trusted custodians. This bypasses the AP oligopoly entirely.\n- Eliminate Counterparty Risk: Math and cryptography replace legal promises.\n- Unlocks Utility: Native BTC can be used in DeFi across Ethereum, Solana, Cosmos in real-time.

~0
Trusted Parties
Real-Time
Settlement
counter-argument
THE MARKET MECHANISM

The Steelman: Why APs Are Necessary (And Why It's Still Flawed)

Authorized Participants are a necessary market-making mechanism for ETFs, but their exclusive privilege creates systemic fragility and hidden costs.

APs provide essential liquidity. They are the only entities that can create and redeem ETF shares in large blocks, directly with the fund. This arbitrage mechanism is the primary tool for keeping an ETF's market price aligned with its Net Asset Value (NAV). Without this, ETFs like a spot Bitcoin ETF would trade at massive, persistent premiums or discounts.

The privilege is a single point of failure. The system concentrates power in a handful of large banks like JPMorgan and Goldman Sachs. This creates systemic counterparty risk, where the failure or withdrawal of a major AP could fracture the arbitrage mechanism and destabilize the entire ETF market. It is a permissioned layer in a supposedly open market.

The cost is hidden in spreads. While APs profit from arbitrage, their oligopoly allows them to widen bid-ask spreads beyond competitive levels. The retail investor pays this liquidity tax indirectly. In crypto, decentralized exchanges like Uniswap V3 or aggregators like 1inch demonstrate that permissionless, atomic market-making eliminates this rent extraction.

Evidence: The GME ETF arbitrage failure. During the GameStop short squeeze, APs halted creations for certain ETFs, causing prices to detach over 30% from NAV. This proved the mechanism is not a guarantee; it is a fragile, discretionary service that fails under stress, unlike a smart contract's deterministic execution.

future-outlook
THE HIDDEN COST

The Path Forward: Disintermediating the Gatekeepers

ETF Authorized Participants create a privileged, rent-extractive layer that blockchain settlement can eliminate.

Authorized Participants (APs) are rent-extractive gatekeepers. They are the only entities legally permitted to create and redeem ETF shares, controlling the arbitrage mechanism that keeps ETF prices aligned with Net Asset Value (NAV). This monopoly on liquidity creation extracts fees and creates systemic fragility, as seen during market stress events.

On-chain settlement bypasses APs entirely. Protocols like Chainlink Proof of Reserve and MakerDAO's tokenized treasury bills demonstrate direct, verifiable asset backing without a centralized arbiter. A tokenized ETF's creation/redemption becomes a permissionless smart contract function, open to any arbitrageur.

The cost savings are structural, not marginal. Removing the AP layer eliminates their spread and operational fees. This directly increases yield for the end holder, turning a cost center into protocol revenue or staking rewards, similar to how Lido or Rocket Pool disintermediate staking services.

Evidence: The traditional ETF arbitrage spread for APs is 5-50 basis points. A fully on-chain, automated system reduces this to near-zero, capturing that value for the protocol and its users.

takeaways
THE AP OLIGOPOLY

Key Takeaways

The ETF plumbing that enables creation/redemption is a centralized bottleneck, creating systemic risk and hidden costs for the entire crypto market.

01

The Problem: APs as a Systemic Single Point of Failure

A handful of TradFi giants (e.g., JPMorgan, Goldman Sachs, Citadel) control the Authorized Participant role. This creates a centralized failure vector for the entire $100B+ spot Bitcoin ETF market. Their operational risk becomes crypto's systemic risk.

~5-10
Dominant APs
$100B+
Exposure
02

The Hidden Tax: Rent Extraction via Arbitrage Spreads

APs profit from the arbitrage between ETF NAV and spot price. This isn't a free service; it's a hidden tax on ETF flows extracted via wider spreads and fees, ultimately paid by end-investors. Their privilege is a revenue stream, not just infrastructure.

  • Basis capture on every creation/redemption
  • Market-making profits subsidized by exclusive access
10-30 bps
Typical Spread
Pure Rent
Revenue Model
03

The Solution: Permissionless On-Chain Primitive

The end-state is a decentralized, programmable creation/redemption mechanism. Protocols like Chainlink CCIP, EigenLayer AVS, or native L1/L2 bridges could enable any qualified entity to become an AP, breaking the oligopoly.

  • Reduces systemic risk via decentralization
  • Lowers costs through competitive, algorithmic markets
0
Whitelist Required
>50%
Potential Cost Save
04

The Catalyst: Regulatory Arbitrage for Crypto-Natives

This isn't just about Bitcoin ETFs. The same AP model will be demanded for tokenized RWAs, treasury bonds, and equities. Crypto-native institutions (e.g., Anchorage, Coinbase Custody, Figment) can bypass TradFi gatekeepers by building compliant, on-chain AP networks first.

Next Frontier
Tokenized RWAs
First-Mover
Advantage
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