Subject: File Number SR-CboeBZX-2018-040
From: Sam Nassiri
Affiliation:

Sep. 21, 2018

Dear Sir/Madam:
 As an experienced trader in the stock market as well as Futures, market for many years, and as an interested investor in Bitcoin, and as a research-oriented individual who is able to convince anybody that the only type of ETF (in any market) which really has potential to be a practical investment tool would be physically based ETF's, I would like to comment on the following issue, regarding the decision to be made on the approval/disapproval of VanEck SolidX Bitcoin Trust:
 “4. What are commenters’ views, generally, on whether the proposed ETP would be susceptible to manipulation?”
 In my opinion, Big Manipulators might abuse the Futures market to manipulate any underlying assets in expense of small traders, by forcing them to liquidate their positions through taking short term large position (due to the nature of Futures market in which extreme leveraging is possible). Therefore, I think the existence of any long term and or cash-based investors such as those investing in physically based ETF's specially this Bitcoin ETF would help the whole Bitcoin market in general (across all exchanges as well as Futures Bitcoin market) to fight against Big guys manipulations of the market.
 Additionally, I think this particular Bitcoin ETF is less susceptible to manipulation, due to the fact that this ETF attract many Bitcoin investors who are cash-based as well as long-term investors; therefore they are less prone to manipulation using short-them high-frequency trades.
 
As a matter of fact, more than any other areas of trading, a very nice cooperation and information exchange is conducted among the whole Bitcoin community. Let me just finish my comment by mentioning that, as a pre-caution measure, the first advise that brokers in this market give to their clients is this: "In this market, please only invest the funds that you afford to lose entirely".