Subject: File Number SR-CboeBZX2018-040 -- Comment
From: Scott Pool
Affiliation:

Sep. 20, 2018

Hello SEC, 


Thank you for your continued research into whether a BTC ETF should be approved. I would like to comment on the manipulation concerns noted in the latest release, and provide some warnings: 

The crypto market right now continues to be heavily manipulated. Bitmex, a foreign exchange that allows users to Long/Short BTC with high (up to 100x) leverage, has been seen having a massive affect on the market. Just last month, they had an announced maintenance and would be down for 30 minutes. The INSTANT it went down, BTC had a nearly $1000 rise. Bitmex admitted themselves to trading against their users as well.  


A market that can be so easily swayed like this is not something that I feel would be safe yet for institutional investors. Retail investors? Sure, if people want to jump in knowing the risks. However, this asset class is still so young and illiquid, that I can't see how VanEck proposes to erase the rampant manipulation still in the market.  


I am for waiting for actual adoption of crypto, and wait for things to recover, before considering an ETF approval.  


Thank you.