Subject: For: File No. SR-CboeBZX-2019-004
From: Louise Fitzgerald

Mar. 19, 2019

Dear Commissioners,  


I believe that manipulation by the exchanges and custody issues are not yet satisfactorily resolved for a Bitcoin ETF/ETP approval.  


For example, in an article published today (03/19/2019), it states that "87 percent of Cryptocurrency Exchange Volume Is Potentially Suspicious" (Source: 


A couple of noteworthy comments were: “In total we estimated that 87% of exchanges reported trading volume was potentially suspicious and that 75% of exchanges had some form of suspicious activity occurring on them,” 


“If each exchange averaged the volume per visit of CoinbasePro, Gemini, Poloniex, Binance, and Kraken, we would expect the real trading volume among the largest 100 exchanges to equal $2.1 (billion) per day. Currently that number is being reported as $15.9 (billion).” 


I do not see how, if the root causes are not identified and eliminated, then an ETF/ETP based on this product will not only fail to solve them but in turn compound them before any real meaningful sustainable risk measures and failsafe's have been identified and implemented to guarantee investor protection. This is the primary objective at the end of the day (think Bull Whip Effect as everyone piles onto the bandwagon)? 


I would respectfully ask you to decline this ETF/ETP for the time being. 


Warm Regards, 

Louise Fitzgerald