Subject: File No. SR-CboeBZX-2018-040
From: Dan Scruggs

July 31, 2018

The establishment of a Security Fund that trades crypto currency assets I believe should not be undertaken. I base this on the basis of such "currency" in this case bitcoin. The establishment of a fund should be based on assets that have an acknowledged Physical and intrinsic value be it a commodity such as corn or a company with an established monetary worth. Crypto Currency has neither as it is a non physical combination of data stored in computer memory or on a data storage device. It is "Volatile" in that a computer crash, hard drive failure, or the "spilling of coffee" on the computer can disrupt the status of a bitcoin transaction or destroy a wallet with no indication that the "data" ever existed along with the fact that the Hacking of these "assets" is a constantly occurring event with news detailing the larger losses. Crypto Currency was created to circumvent currency utilized by each country and disrupt the tax base by utilizing concealed transaction portals that didn't involve standard financial institutions. The processing of bitcoin and other cryto currency is done by "exchanges" that aren't regulated by Government Agencies and as such could create an unstable financial situation within a fund creating havoc for investors that aren't fully aware of the unstable makeup of this asset.