Subject: SR-CboeBZX-2018-001
From: Don Krohn

April 7, 2018

To the Commissioners,

Concerning proposals for Bitcoin ETFs, I believe they should be structured in a traditional manner, i.e., though fund ownership of the actual underlying asset (the currency) directly, rather than being based on futures or other derivatives. Basing cryptocurrency ETFs on derivatives would invite manipulation of prices and increase the risks of unacceptable levels of volatility, which have been the Commission's stated concerns. Recent events such as the collapse of inverse volatility ETFs highlights the potential dangers of over-complex derivative-based funds. A "plain vanilla" asset-based Bitcoin (or other cryptocurrency) ETF would be simpler, more transparent, and less subject to complex and destabilizing trading strategies. I think this would far better serve the investing public, and I urge the commissioners to take this into consideration.

Thank you.

Don Krohn