Subject: File No. SR-CboeBZX-2023-038
From: John Rundle
Affiliation: Professor of Physics

July 18, 2023

It's high time to approve a spot bitcoin ETF. As is well known, futures contract must converge on the spot price at expiry. So if there is fraud in the spot price, there will be fraud in the futures contract price. It makes no sense of the SEC to have approved futures bitcoin ETF but to deny spot ETFs, based on the assumption there may be fraud in the underlying spot, but not in the futures price.