Subject: File No. SR-CboeBZX-2018-040
From: Andre Rademan

July 14, 2018

To whom it may concern,

1. It is a fact that wealthy individuals will increasingly invest in Bitcoin as they have in the past but this will only gain momentum going forward. It is far better that this is done as an EFT because then the funds are in the financial system and taxed.

2. If a financial advisor/broker is not able to assist their client then the adviser/broker might be bypassed which fragments the portfolio and it fails to be a 360degree solution balancing risk amongst the asset classes. This is detrimental to the broker's relationship with their client, the broker's business having to deal with fragmented portfolios, and also the client's investment strategy if the portfolio is not balanced.

3. The 25BTC minimum level will make it more likely that proper advice by a financial adviser/broker took place, instead of the transaction taking place on an exchange directly by an individual.

4. An EFT will be a safer process for a client to acquire and hold Bitcoin because they will not have to contend with navigating a myriad of security best practices which are very difficult to do 100% right, even for someone with above average technical skills. The EFT in question removes this risk entirely.

Andre R