Subject: Comments on SR-CboeBZX-2018-040
From: Minas Kastanakis
Affiliation:

Oct. 13, 2018

To: SEC 

It is lately becoming clear that Bitcoin (and Cryptocurrencies) are slowly becoming the efficient standard for the transfer of funds as well as a store of value. Despite the current volatility, with the growing interest by major institutions and endowments, any clearly laid out regulations and instruments - such as the ETF under consideration - will aid this new technology reach towards its efficient frontiers and provide a new avenue for investment that the common person with an iPhone or laptop can easily access *safely and securely*. 


Right now - without an ETF - investing in Bitcoin through unregulated exchanges is quite risky for retail investors. Hence having a regulated vehicle such as the proposed ETF, backed by PHYSICAL & INSURED Bitcoin, is the safest way for qualified (and retail) individual investors to gain access to this new and developing asset class. 


I understand that the Bitcoin market runs counter to all established thinking in modern financial markets regulation. This is because, until now, markets have always been created from the top-down whereas Bitcoin is the only financial market that emerged bottom-up. But this NOVELTY is not a reason for the SEC to so nothing. As Commissioner Peirce correctly stated, the role of securities' regulators is not to be gatekeepers of innovation but to protect investors. 


As a final comment, A Bitcoin ETF will be a huge step towards better understanding of its global impact and a plus for the US financial sovereignty [vs. emerging competitors such as EU (Malta, Estonia Switzerland etc.) or China] and it's something worth to try. The SEC must recognise that careful steps to implement ETF products on Bitcoin is something that improves its reputation as a regulating body that cares of the US and Global Markets. 


Thus I encourage SEC to approve this ETF backed by physical bitcoin. 


Thank you. 


Minas N. Kastanakis, Ph.D. 
Professor of Business, ESCP Europe 

Editor-in-Chief, European Management Journal​ ​ 
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