Subject: File No. SR-CboeBZX-2018-040
From: Grady Ryther

October 10, 2018

I have researched and monitored the cryptocurrency space for more than a year. I strongly urge the SEC not to approve any Bitcoin ETF until the markets have significantly more regulatory oversight. There is rampant manipulation on most foreign crypto exchanges. Even Kraken, a US exchange, allows wash trading. Spoofing is another very common practice on these exchanges. Most also do not require any KYC/AML procedures to start trading, even for American customers (e.g. Binance).

The biggest offenders are Bitfinex and Tether, which are run by the same people. Tether is almost certainly fraudulent, as evidenced by their failure to complete a single audit, and their shady banking relationships. Without regular official audits, Tether cannot and should not be trusted to have 1:1 USD:USDT reserves. I believe they are printing USDT without receiving any USD, and propping crypto prices up artificially.

Without shutting Tether and Bitfinex down, along with all non-KYC exchanges, the manipulation and money laundering constantly taking place without regulatory oversight is a huge problem for launching an ETF. After the space is cleaned up, and proper regulations are put in place, then and only then should a Bitcoin ETF even be considered.

Thanks for your consideration.