Subject: SR-CboeBZX-2018-040
From: Ben Burden

July 11, 2018

The two most significant hurdles for investing in digital assets are (1) taking on the role of custodianship and (2) the technical ability that is required to make the purchase.

- Broadly, the early investors that benefited from this growing digital asset class had an above average level of technical ability.

- More recent investors require confidence in their technical abilities but can at least leverage the expertise of the early adopters and follow in their footsteps. It remains a big step to take custodianship for these assets.

- Today, solutions are appearing for large/institutional investors that overcome these two hurdles by offering custodianship and simple methods of purchase.

An underserved group of retail investors remains to date that have been unable to overcome these two hurdles. Where ETF’s have traditionally served this group in other asset classes, the response has been unfortunately slow in the case of digital assets.

A Bitcoin ETF addresses two fundamental failures of the digital asset market today. Retail investors deserve more opportunity to gain exposure to the secular growth that is arising from individuals, companies and governments orientating themselves around distributed networks.

Thank you for your time,
Ben