Subject: File No. S7-15-18
From: Chaz Falcone

July 31, 2018

1. Get rid of the concept of mid/ask spreads and just have a price for securities. Spreads are a sham to pay large fees to brokers and market makers and yet they can still advertise $7.95 trades. Create a single price for securities and then have a true fee that reflects whatever the trading costs are. I know this would require a major shift in market structures, but stop hiding the ball from investors, most of which do not even realize there are two prices for a security.

2. Let bitcoin ETFs exist. I hate them, but if folks want them, give them a regulated way to access them.

3. Require funds to disclose tracking error for any indexed ETFs and require strong adherence to the index. 80% seems lax.

4. Figure out how to make reinvestment of dividends work. Folks who own ETFs must constantly find things to do with the dividend income that is thrown off. Vanguard's structure can reinvest the dividends, but all ETFs should have some mechanism. (Yes, I realize it is difficult to deal with fractional shares.)