Subject: SR-CboeBZX-2018-040
From: Bobby Mulligan
Affiliation:

Oct. 10, 2018

Dear members and representatives of the Securities and Exchange Commission ("SEC"). 

I would like to express my strongest opposition against allowing Bitcoin ("BTC") Exchange Traded Funds ("ETF's"). 


BTC shows little promise for being effective as a "store of value" or medium of exchange with its transaction costs being much more than the current centralized clearinghouse model that is in place today. Additionally, there is no accountability for transaction clearing, which can be concerning on many fronts. With little more than speculative supply and demand value, the average unaccredited investor can suffer from the "greater fool" phenomena.  



In its unregulated and short existence, BTC has existed in an environment of fraud, crime, and speculation, and I do not believe there is true investor value outside of those three factors for the asset. Because of the high transaction expenses, there are no reasonable efficiencies to be had from the BTC technology, though refinement and other applications may exist. 




Sincerely,  
Robert Mulligan