Subject: SR-CboeBZX-2018-040
From: Suranga Suraweera
Affiliation:

Jul. 23, 2018

Valuation: Futures pricing been consistent with actual Bitcoin pricing. Current Futures pricing is based on a large range of open exchanges. Arbitrage creates a checks and balance Bitcoin eco system Liquidity: There are over 25+ major Bitcoin exchanges in US. Liquidity should be no problem from ETF since the purchases will be made as a combination of open exchanges and over the counter systems. Custody: Security AND Insurance are provided in current ETF proposal. Storage is spread across several ETF custodial services.
Arbitrage: Between the maturity of CBOE / CME futures trading, open exchanges, and over the counter systems, there should be no concern about arbitrage to make sure price is consistent. If any particular area has a price variation, selling / buying to equalize the ecosystem is readily mature.
ETF's are the answer to market fairness. All markets have a potential for manipulation. There are 128 commodities. All capable of being manipulated by major players. What actually reduces the chance for manipulation is to increase competition among the big players. There are 1700+ ETF's in the US all competing for these commodities. Approving a Bitcoin ETF will lead the way for multiple other ETF's to join the financial ecosystem.

Best regards,

Suranga Suraweera