Subject: File No. SR-CboeBZX-2020-070
From: Jay Soloff
Affiliation: Lead Options Analyst, Investors Alley

December 30, 2020

A -1x Short VIX Futures product is an important vehicle to have available for sophisticated investors and advisors. Currently, the most prominent way to replicate this strategy is to short VXX (or a similar instrument), which introduces a host of additional risks. Being able to directly invest in an inverse volatility product can serve as a potential stock replacement strategy or a way to diversify equity exposure. It will be a welcome and necessary addition to the ETF space.