Subject: File No. SR-CboeBZX-2018-039
From: Tom Holt

July 11, 2018

I support the creation of ETFs and other cryptocurrency-based financial instruments because 1) accessing crypto markets provides value to society and 2) there are currently significant barriers to entry blocking people without technical skills from accessing those markets.

1) Crypto markets provide value to society:

Cryptocurrency markets have value because, among many other uses, blockchain technology allows for: a) a hedge against the collapse or devaluation of a national currency as seen in Zimbabwe and Venezuela b) more efficient tax auditing c) labor-saving smart contract technology d) digitalization of property deeds e) distributed autonomous organizations (which can comply with SEC regulations in the future) f) a more cost-efficient alternative to credit card transactions

2) Significant barriers exist for retail investors:

Setting up an account on ETRADE is much easier than learning about the differences between leaving crypto assets on an exchange versus using hardware wallets, paper wallets, web wallets, or desktop wallets.

Hackers and criminals profit from scamming people with a lack of technical expertise. User error results in the mistaken loss of assets.

For these reasons and more (including Japan's head start in this area) I support the creation of cryptocurrency ETFs, including this Bitcoin ETF.