Subject: File No. S7-15-18
From: Todd N Handel
Affiliation: Finance consultant

July 12, 2018

I first want to commend the careful consideration that the SEC has leveled at the crypto currency space. I think it is fair to say that the entire world was caught off guard over the last 12 to 18 months and that the concepts and principles that are presented by digital assets in crypto currency are as forward thinking as they are potentially mind blowing. But after having had time to dig deep and study the potential of digital assets, it is clear to us in the financial industry that five years from now we wont be saying crypto currency we will simply be saying Currency.

The current state of the futures markets is both ambiguous and has the potential for fraud in that the markets are cash settled and only marginally correlated because there is no demand for delivery nor holding of the underlying assets. ETFs would add an incredible amount of safety to this market by forcing participants on all sides to hold the underlying assets. Without the holding of these underlying assets, you would have markets that are completely untethered and open to wide scale manipulation.

The CBOEs ideas for an ETF have incredible marriage, and it is our wish that you would get behind this, and stability and liquidity two markets that are waiting for such.

Thank you for your time and careful consideration