May 29, 2025
Dear SEC, I am writing in strong support of the proposed rule change to allow the listing and trading of shares of the WisdomTree XRP Fund on the Cboe BZX Exchange. 1. Consistency with the Exchange Act The proposal aligns with Section 6(b)(5) of the Exchange Act, which requires exchanges to maintain fair, orderly, and efficient markets. The WisdomTree XRP Fund seeks to track the performance of XRP based on the CME CF Ripple-Dollar Reference Rate (New York Variant)—a regulated and reliable pricing benchmark already used in institutional markets. This benchmark ensures transparency and consistency, mitigating price manipulation risks and satisfying fair market principles. 2. Fraud and Manipulation Safeguards Concerns about manipulation are mitigated by several key factors: XRP is widely traded across global markets with significant liquidity, reducing susceptibility to market manipulation. WisdomTree's trust structure includes a third-party custodian and a cash-based redemption system (no in-kind transfers), both of which limit the risk of fraud or improper asset movement. The underlying pricing benchmark reflects multiple trading venues, ensuring robustness and reducing reliance on any single exchange. Additionally, similar crypto-based commodity trusts (e.g., BTC and ETH ETFs) have already been approved, setting a regulatory precedent for responsible digital asset fund structures. 3. Investor Protection and Public Interest Approving this product enhances investor access to regulated, compliant exposure to XRP through traditional brokerage accounts—removing the need to self-custody crypto assets. This reduces counterparty, custody, and cybersecurity risks often associated with retail participation in unregulated markets. It also offers diversification options in a secure, institutionally-backed format. Furthermore, WisdomTree is a well-established sponsor with a record of regulatory compliance and transparent fund management. Allowing XRP to join the same ranks as BTC and ETH through a public trust fund encourages regulatory clarity and fosters U.S. competitiveness in financial innovation. Conclusion This proposal represents a natural progression in digital asset integration within regulated U.S. markets. I respectfully urge the SEC to approve SR-CboeBZX-2025-019, as it satisfies statutory requirements, mitigates manipulation risks, and serves the public interest. Sincerely, Sam