Subject: SR-CboeBZX-2018-040
From: Leeor Shapira
Affiliation:

Sep. 23, 2018

Regarding the status of the Van Eck Solid-X Bitcoin ETF, please take into consideration the fact that the fund will have a high initial investment requirement as well as having insured physical bitcoin. This should alleviate any concerns regarding custodianship. Furthermore, it is disingenuous to continue to highlight market manipulation. First and foremost anyone investing in BTC should be well aware of the fact that the bitcoin is traded on open exchanges as well as otc. While wash trading remains a concern, it is incumbent upon a governing body to ensure that regulations are in put in place that would hold such transactions accoiuntable, both through AML and KYC, and a reporting mechanism be put into place. For all of the concern around such topics in light of this being a digital asset, such reporting should be relatively easily achieved. That in my opinion begs the questions of whom is to enforce such policies and when do they get put in place. 


As far as any debate regarding manipulation, let us not forget there is a black market for US Dollars as well. That does not hinder one from using, purchasing, and selling US Dollars and in all it's history did not require any governing body to step in to stop the purchase of US Dollars.Please see below regarding this. 
https://www.dailynews.co.zw/articles/2018/06/28/us-dollar-black-market-rate-soars 



In light of all this, I believe it is time to request an AML/KYC policy and monitoring from exchanges that would ensure the rights of investors are protected. While this may result in the ETF being denied, if the community is to self-regulate it is incumbent upon a governing body to lay the framework for such regulation so that compliance can be achieved. Without it, it is much like a child floundering to swim in a pool without a swimming lesson. Thank you for your time and consideration.