Subject: 34-83520 File No. SR-CboeBZX-2018-040
From: Fan Xia
Affiliation:

Oct. 11, 2018

Dear SEC commissioners; 

In regards to recent Bitcoin ETF approval, I would like to express support for such product to be approved. I would also like to make an argument that the current decisions to denied such product is unreasonable. 

Previously, the primary reason for denying such product was due to manipulations in the underlying market of Bitcoin.  It is my understanding that the SEC feels the underlying market must be more mature first and that the Bitcoin market have better standards as well as prove that the underlying market is resistant to manipulations. 

Respectfully, the SEC has no jurisdiction over the entire world.  Bitcoin as an asset is global and it is exchanged in various countries.  How will the SEC ever be able to be certain that the Bitcoin market will no longer be manipulative?  Such task is impossible and such requirement becomes unreasonable.   

Even if the SEC waited years for the Bitcoin market to become mature, manipulation could not be avoided completely as it is in human nature to be manipulative to take advantage of others.  The SEC cannot ensure that each corner of the world is not manipulative.  For the reasons above, the SEC cannot ensure the underlying Bitcoin market will ever be resistant to manipulation.   

Therefore, the reason for denying the Bitcoin ETF based on the concern that the market is susceptible to manipulation is unreasonable and the current decisions to denied Bitcoin ETF was unjust.   

Furthermore, while everyone at the SEC have their heads down looking closely at the Bitcoin market and the Bitcoin ETF applications, we should not forget that the SEC stances are or may dampening the entire crypto space.   More importantly, crypto currency and Blockchain innovations that can transform the future of our society and its importance far outweighs the concerns the SEC had over the underlying Bitcoin market.   

Therefore, I urge the SEC commission to treat Bitcoin ETF fairly and keep in mind the greater crypto and Blockchain innovation space is more important.  It is critical the SEC shows support and clarify the rules for the entire space to conduct itself lawfully. 

Fan Xia 
Rite-Hite Holding Company 
Lotus Notes Application Administrator