Jun. 16, 2021
Dear Commissioners: In response to today's request by the SEC for additional comments regarding the VanEck Bicoin Trust (Release No. 34-91326) as it relates to BZX Rule 14.11(e)(4), I would recommend to the Commission that it accept the proposal so as to protect American investors from undue volatility caused by asymmetric buy/sell-side access in crypto markets. Many American retail traders have taken exposure now that it is relatively easy to do so via brokages like Robinhood, or even money management apps like Square's Cash App, but one thing is much harder to get access to by non-institutional market participants: Short exposure. We can be certain that this has some amplifying effect on the price action, likely adding unnecessary tailwind to a standard asset bubble, and it is my belief that the SEC should protect the integrity of the markets and safeguard American investors from price manipulation by giving participants easy access to exposure via a publicly listed ETF. In my view, it is extremely important that rule changes allowing this ETF, and similar ETFs, be approved. I would extend this argument to crypto exposure more broadly, and recommend that the SEC consider any proposal for a broader market portfolio ETF (rather than just Bitcoin) similarly. The longer these things are delayed, the more exuberance that is packed in, and the more volatile these assets will be on both sides of the cycle. Respectfully, C. Lewis