Subject: File No. SR-CboeBZX-2018-040
From: Andre Rademan

October 2, 2018

To whom it may concern,

Comments are being solicited on many questions, but broadly the following question is being asked "What are commenters views, generally, on whether the proposed ETP would be susceptible to manipulation?"

1. My view is that it is much easier for the share price of one company, like TESLA, to be manipulated by a CEO, publicly in the media, than it would be for the price of bitcoin to be manipulated by a single party.

2. Manipulation is often blamed for normal market forces. There might be fear that the price might drop and a party with a significant position might sell, taking advantage of the irrational fear while purchasing again at a lower price. In exactly the same manner there might be irrational euphoria and investors will take advantage of this knowing that the optimism is not based on fundamentals and the price will correct again lower. This is all part of the market.

The longer term institutional and large private investor that this product is aimed at would not be concerned with such short term price swings. It is safer to invest in the underlying commodity because there is less manipulation than high risk companies with unproven products and which is highly susceptible to insider trading.

3. Now that the investor decided to invest 1% in the Crypto industry and the investor RIGHTLY concluded that the safest place to do such an investment is directly into the Bitcoin commodity, what is the easiest and safest way for this investment to occur?

Up now now it has been very difficult and unsafe for a financial advisor who doesn't know what they are doing. It is like expecting a financial advisor to purchase large quantities of gold leaf on the streets, and to keep it safe on behalf of the client

This is not protecting the industry. The relationship between the financial advisor and client is fractured because the financial advisor can not assist, even though Bitcoin is in the headlines almost weekly. Additionally, the client is forced to navigate the complicated world of security and 2FA on exchanges themselves.

Why not allow long-term investors to diversify their portfolio in a safe and insured manner through their regular financial advisor, receiving advice and balancing a portfolio properly?

This is protecting investors.