The market is very loud, but still very tiny. This will change, and it's good to start early, but I agree wholeheartedly that an ETF is premature.
This will not be the case in 12 months, though.
I think the biggest risk to a fund like this is data security. If you have more than 50k bitcoin sitting around, APT doesn't even begin to describe the measures people will take to steal your keys.
Their S1 specifically states that the fund is not holding the Sponsor company (holding the keys) liable should their proprietary Security System fail and the keys get hacked and the coins are stolen unless it was gross negligence.
This is going to be a bumpy ride for those who don't have a deep understanding of security surrounding crypto. Based on some of the technical mis-descriptions in this doc, I am tempted to speculate that they may not have the requisite understanding to fully model the threats they face. Then again, government paperwork takes months, and perhaps this is just an early step and they'll source all of that in the interim. (Hey, tall dudes: I've got 15 years of experience keeping private data away from super-determined hackers and other bad guys, and my email address is jp@eeqj.com! Get in touch!)
The filing says nothing about the details of their proprietary Security System.
Following that, the future of liquidity is a huge unknown void right now. I wouldn't be surprised if at some point in the next 12 months, there are no exchanges on which you could liquidate more than $50-$100k in bitcoin.
It's even difficult right now when everything is nominal - anyone who thinks buying a few million dollars in bitcoin is easy or simple has never even begun to try to do so.