Subject: SR-CboeBZX-2023-028: Webform Comments from Jason Grunstra
From: Jason Grunstra
Affiliation:

Aug. 15, 2023

Regarding the following:
Ark 21Shares Bitcoin ETF, File No. SR-CboeBZX-2023-028 
Invesco Galaxy Bitcoin ETF, File No. SR-CboeBZX-2023-038 
iShares Bitcoin Trust, File No. SR-NASDAQ-2023-016 
Valkyrie Bitcoin Fund, File No. SR-NASDAQ-2023-019 
VanEck Bitcoin Trust, File No. SR-CboeBZX-2023-040 
WisdomTree Bitcoin Trust, File No. SR-CboeBZX-2023-042 
Wise Origin Bitcoin Trust, File No. SR-CboeBZX-2023-044

I wish to express strong support for approval by the Securities and
Exchange Commission (Commission) of the seven proposed
rule changes referenced above, which were filed pursuant to Section
19(b)(1) of the Securities Exchange Act of 1934, as amended (the
Exchange Act) and Rule 19b-4 thereunder to create a spot
bitcoin exchange- traded fund (ETF). I encourage the
Commission to approve the proposed rule changes, and I disagree with a
recent letter from Grayscale Investments, LLC (Grayscale)
suggesting that the Commission's approval of those rule changes
would improperly grant an unfairly discriminatory and
prejudicial first-mover advantage to these proposals.

The Commission's previously-stated concerns with respect to
market manipulation are well-addressed by the above-referenced
applications. I disagree in the strongest terms with Grayscale's
assertion that the Commission may hold up applications that meet the
Commission's standards so that other market participants can
catch up.

The Rule 19b-4 application process is well-known and understood by
market participants. Under the process for seeking exchanges
rule changes, the Commission is required to provide responses and take
action within specified time periods. Section 6(b)(5) of the Exchange
Act provides the standards under which a rule change must be measured,
and the Commission is required to consider whether an application
meets those standards on the merits of the terms of the individual
application.

I recognize that Section 6(b)(5) requires, among other things, that
the rules (including rule changes) of an exchange must not be
designed to permit unfair discrimination between customers,
issuers, brokers, or dealers." The pending 19b-4 applications, if
approved, would not discriminate between issuers – all issuers could
revise their practices to comply with the rules, as amended.

Section 6(b)(5) does not say that the prescribed time periods for
granting of applications should be set aside to allow all market
participants to have their pending proposals approved on the same
timeline. Indeed, the Commission does not have the ability to pause
its review of filed rule changes. The timeframe for the
Commission's review and actions are specified in Section 19(b) of
the Exchange Act. My view is that it would be a mistake, and likely a
violation of the Exchange Act, to read other provisions of the
Exchange Act and the Administrative Procedure Act to override the
standards in Section 6(b)(5) and the time periods attendant to
approvals of 19b-4 applications, in furtherance of preventing a
theoretical first mover advantage. Not surprisingly, the Commission
has not done such a thing in the past.

The investing public deserves access to spot bitcoin ETFs that meet
Commission standards. The Commission has previously expressed concerns
around market manipulation with respect to the operation of spot
bitcoin ETFs. An executed surveillance sharing agreement with
Coinbase, Inc., in my view, adequately addresses those concerns. As
such, we encourage timely approval of applications with executed
surveillance sharing agreements.