July 12, 2018
In regards to SR-CboeBZX-2018-040, after evaluating the proposed EFT, I recommend The United States SEC approve such proposal for the following reasons.
The proposed ETF is Bitcoin only which SEC has formally declared none security, and Bitcoin will be regulated by CFTC as a form of currency or commodity. This means the product can fulfill the requirements of the laws of The United States both the EFT as security and Bitcoin as currency or commodity.
Investment into the ETF shares are backed by physical Bitcoin, No leverage, mostly traded OTC and or exchange as appropriate. This is equivalent to direct and fair investment with no leverage which removes the related leverage risk for investors. It's a plus with no additional risk related with leverage.
Bitcoin price index are available to track performance. On top of that, cold storage and multi signature wallets are best practices of the industry. Such practice is most secure much like traditional custody of storing gold in vaults. In my opinion, secure storage is sufficient on top of insurance policies that provided assurance to investors.
Target investors are institutional with higher entry which means investors are generally professional and well informed of the risk involved versus average person who might be gambling with their money. Therefore, such product Bitcoin ETF is sound and it operates within the laws of The United States.
For the above reasons, I highly recommend SEC approve because it was a well designed product that is safe for investors. Additionally, as investors, people should be allowed freedom to invest into what they believe in. I appreciate SEC concerns over safety of such product, but I like to remind everyone SEC role is a lifeguard on the beach, not the gate keeper. Here in The United States of America, we enjoy freedom and uphold freedom to high standards. Our freedom to invest into what we believe should be upheld by the same standard as well.
Sincerely,
Fan Xia
Rite-Hite Holding Company
Lotus Notes Application Administrator