Looks like BlackRock met with the SEC's Trading & Markets division again yesterday and gave presented them with a "revised" in-kind model design based on Staff's comments at their 11/20 meeting.. h/t @btcNLNico here's full doc: sec.gov/comments/sr-na…

Here's the original vs revised in-kind model, look like the new thing is STEP 4, which is the offshore entity market maker getting bitcoin from Coinbase and then pre-paying in cash to the US registered broker dealer (who is not allowed to touch bitcoin).$BTC