Subject: SR-CboeBZX-2018-040 Cboe BZX Rulemaking
From: Mark Kramm

July 11, 2018

In response to the request for comments for SR-CboeBZX-2018-040 as a new ETF over the counter product, I would like to propose the following comments:

I suggest action be taken to start approving ETFs versus inaction which appears to be more damaging to investors.

Mark Kramm