Subject: File No. SR-CboeBZX-2018-040
From: David Gerbitz

July 11, 2018

I support the proposed rule change to permit registration of SolidX Bitcoin Shares on the CBOE BZX Exchange. The proposed listing would enable retail and institutional investors to more easily obtain exposure to bitcoin, the most liquid and widely traded cryptocurrency in the world.

The SEC should consider that the Commodity Futures Trading Commission (CFTC) has already approved bitcoin futures for trading on the CFE and CME futures exchanges. Thus, there is precedent for a federal agency approving bitcoin-related products for trading on regulated exchanges. The proposed bitcoin ETF would expand access to bitcoin beyond the institutional investors who primarily participate in the futures markets.

One common objection involves whether a bitcoin ETF is suitable for retail investors given bitcoin's historical price volatility. Current regulations require investment professionals to assess whether investments are suitable for clients before making recommendations or allowing access to products on self-directed trading platforms. These safeguards should be sufficient to restrict the proposed bitcoin ETF to investors capable of accepting the risk of speculative investments.