Jul. 02, 2021
From: Vetle Andreas Gusgaard Lunde <vetle@arcanecrypto.no> Sent: Friday, July 2, 2021 8:02 AM To: Rule-Comments <Rule-Comments@SEC.GOV> Subject: File No. SR-CboeBZX-2021-019 U.S. Securities & Exchange Commission, This comment serves the purpose of shedding light on CME's role in bitcoin's price discovery. (Proceeding 4a) . Price discovery in bitcoin (The academic paper will be shared upon request): https://www.research.arcane.no/blog/the-regulated-tail-that-wags-the-honey-badger We have recently conducted a study on the price discovery in bitcoin from June 1st, 2020 until April 30th, 2021. In the study, we conclude that the Bitcoin futures on CME has a far more pronounced leadership role in bitcoin's price discovery now than identified by Carol Alexander and Daniel Heck studying the markets from April 2019 until January 2020 (with similar methodology applied). Our results indicated that the regulated CME futures was leading the price discovery in bitcoin in October 2020 and April 2021, and overall the CME futures was one of the key instruments in bitcoin's price discovery. The regulated markets are becoming an integral part of bitcoin's price discovery. It's in our opinion that this speaks in favor of the current bitcoin ETF applications. Thanks, Vetle Andreas Gusgaard Lunde Analyst at Arcane Research