Subject: SR-CboeBZX-2018-066 - Cboe BZX Exchange, Inc. (CboeBZX) Rulemaking
From: Paul Bichler
Affiliation:

Oct. 26, 2018

Dear SEC, 


I am a businessman and retail investor with a decade of experience working for innovative american companies like Cisco, Salesforce or Oracle. I would like to add my point of view to the pending ETF decision. 


The CEO of crypto investment group Pantera Capital, Dan Morehead is atating that ETFs are not going to be the major catalysts for the overall growth of the cryptocurrency market. 
According to Morehead, investors focused on whether the SEC will approve a Bitcoin ETF are missing the big picture. Morehead says “an ETF is not news” and notes that if past is prologue, it’s far too early for the agency to give an ETF its seal of approval. 


“Very few people know that the last asset class that was certified for an ETF was copper. It took three years, even though copper has been around for 8,000 years.” 


Moorehead says he expects institutional money to begin streaming into the crypto market in the first half of 2019, regardless of the availability of ETFs. Currently exchanges are being developed that are targeted to institutional investors. 
Examples are fidelity, digitex, or Bakkt. So whether you approve Bitcoin ETFs or not, this is not something the SEC can stop, neither for Retail or Institutional investors. 


All the SEC does by postponing it hurts the image of the US as a country that embraces innovation, especially in the IT sector. Also it leaves investors with inferior instruments and fragile exchanges where already billions have evaporated. 


Why is it important to act now vs postponing a decision again? 


The stock market is tumbling after a decade of high growth, investors need to look into alternative assets. Being able to diversify and spread risks is critical. Compared to the stock markets the crypro currency market looks steady now and the prices have consolidated. 


Also please forget that you protect anyone by not making a decision. People will find ways to enter the market. Only will they be limited to less secure instruments on exchanges that are exposed to hackers. 
Also investors need to organize their funds and private keys and there are currently many risks and traps for investors. 


Therefore my strong advice for you: 


Do not to wait any longer, do not make this a Copper 2.0. Look at Sweden, they are a step ahead on this as they implemented an ETF without issues. Sweden is thriving in IT and cloud based companies, the same is true for other scandinavian countries and even Eastern Europe. This technology is transformative and you need to find ways to integrate it in your complex infrastructure rather oppose it. Ultimately you also risk in falling behind. Whats the point of bringing manufacturing jobs back if another sector leaves? 




Disclaimer: Iam not a US citizen but worked more than 10 years in american IT companies and therefore follow economic developments in the US closely. 


Kind regards 
Paul Q. Bichler 


My professional profile 
https://www.linkedin.com/in/pbichler/