Subject: File No. SR-CboeBZX-2020-070
From: Peter Corrigan
Affiliation: Former Managing Director, institutional equity derivatives trader

January 7, 2021

A short VIX ETF provides a simple and efficient method for all investors to initiate short volatility positions. Increasing access for all investors to the short side of the VIX will enhance pricing efficiency and liquidity of all instruments in the VIX universe of listed products (options, futures, long VIX ETFs).

The design of this ETF and the extensive experience in volatility trading of the ETF sponsor will help insure the orderly rebalancing of this product, enhancing price discovery and liquidity of the VIX futures markets.