Subject: File No. SR-CboeBZX-2018-040
From: Paul Jones

August 24, 2018

Dear Chairman and Commissioners,

I am an active cryptocurrency investor and appreciate the technology being an Engineer. However, I have to agree with the decision to recently reject the other Bitcoin ETF's and ask you to do the same with this one.

Apart from the spot market being manipulated the futures market is not exempt from this also.

There have been many case studies which highlight the manipulation of the futures market, for example:

1) In 1990 the US Treasury Securities market, which is one of the world's largest and most liquid markets was manipulated by the Salomon Brothers Inc. https://www.nytimes.com/1991/08/10/business/salomon-brothers-admits-violations-at-treasury-sales.html

2)The Hunts Brothers were sued by Minpeco SA for $150 Million for manipulating the Silver market (increasing the price of Silver from $9 an ounce in July 1979 to peaking just over $50 an ounce in January 1980). https://priceonomics.com/how-the-hunt-brothers-cornered-the-silver-market/

3) In 2008 the CFTC ordered Kansas City, Missouri-based dairy marketing cooperative Dairy Farmers of America (DFA) and two of its former executives to pay £12 million to settle charges of attempted manipulation and speculative position limit violation.

https://www.cftc.gov/PressRoom/PressReleases/pr5584-08

As you can see if these markets can be manipulated then a market such as Bitcoin which is significantly smaller in size and with existing rampant manipulation is not ready for the SEC's approval.

It is not about stifling innovation- that has already happened, it is about due diligence and genuinely protecting investor interests.

Please also see this article which provides a balanced view on this topic: https://www.coindesk.com/before-bitcoin-etfs-pass-a-clear-crypto-narrative-is-needed/

 

Sincerely,

Paul Jones