Aug. 11, 2025
To Whom It May Concern, Roundhill Investments is writing to you to express support of the proposed rule change filed by Nasdaq ISE as outlined in the Federal Register notice (File Number: SR-ISE-2024-35) dated April 15, 2025. Roundhill Investments manages the Roundhill Ether Covered Call ETF (Cboe BZX: YETH), a covered call ETF on Ethereum, which offers investors exposure to the cryptocurrency, subject to a cap, while providing the potential for current income. The entirety of YETH’s exposure is established through listed options, with the majority of holdings using ETHA. However, as Roundhill has met the current position limit sizes in ETHA at 25,000 contracts, YETH utilizes a combination of listed options on both EETH and ETHA. The introduction of FLEX options on ETHA and the proposed increase in position limits to 250,000 contracts would significantly increase Roundhill’s ability to operate YETH efficiently and effectively for investors. The introduction of FLEX options will allow Roundhill substantially better execution in both order handling and precision. FLEX options allow for risk-managed order handling methods, which are not available within listed markets. Specifically, FLEX options allow for a delta-adjusted fill. Delta-adjusting mitigates any potential risk of the underlying asset trading substantially higher during execution by adjusting the final premium fill based on the underlying asset’s reference price throughout the execution. This is not an option within listed option markets and can result in poor execution. FLEX options also allow for customization of strike prices and expirations that align more precisely with the fund’s strategy. This flexibility will meaningfully improve execution quality, reduce slippage, and ultimately lead to a more exact and intentional distribution yield for shareholders. The proposed increase to the current position limits from 25,000 to 250,000 contracts will allow Roundhill to concentrate YETH options activity solely within ETHA, simplifying YETH’s structure from two underlying assets into one. This improvement benefits both portfolio managers and investors, as it enables clearer, day-over-day visibility into the capped upside and risk profile of the covered call strategy. Roundhill Investments believes that these rule changes are a thoughtful and necessary evolution for a growing market in digital asset-based derivatives. Thank you for the opportunity to comment. We strongly urge the Commission to approve the proposed rule changes. Sincerely, Roundhill Investments Registered representative with Foreside Fund Services, LLC which is not affiliated with Roundhill Investments or its affiliates.