Subject: File No. SR-CboeBZX-2018-040
From: Evan Rose
Affiliation: CEO, Aquarius Management Corp

July 11, 2018

The advent of a regulated and transparent Bitcoin ETF would give investors access to a new and growing asset class in a manner which is far safer than existing avenues, particularly for non-technical persons. While there are already myriad ways of obtaining exposure to Bitcoin today, many are contingent on investors trusting opaque -- and often foreign institutions -- where there is little recourse in the event of a loss of funds due to negligence, malfeasance, or theft by a third party.

The opportunity to have exposure to Bitcoin through an ETF as is being proposed here represents a tremendous boon to US investors in the form of a far safer option compared to existing alternatives. With the approval of a regulated US-based ETF, interested investors would no longer need to unnecessarily expose themselves to counter party risk on exchanges and custodial wallet platforms, nor need to obligate themselves to learn the arcane practices of safely storing their Bitcoin private keys.

In consideration of the above, the approval of this ETF would represent a quantum leap forward for US investors, increasing accessibility to an asset class for which they have expressed a clear appetite, while mitigating their exposure to archaic and often inescapable risks that investors must assume given the current lack of a regulated, liquid, and transparent Bitcoin ETF offering.