Subject: SR-CboeBZX-2023-072: Webform Comments from Joe Stevens
From: Joe Stevens
Affiliation: Retired

Nov. 29, 2023

Q1a: What are commenters’ views on whether the proposed
Fund and Shares would be susceptible to manipulation?
A1a: Under responsibility of Fund Managers, the risks are no greater,
perhaps less, under corporate governances similar to those used for
securities.
Q1b: What are commenters’ views generally on whether the
Exchange’s proposal is designed to prevent fraudulent and
manipulative acts and practices?
A1b: Preventing fraud, under any circumstances is not an activity that
can be regulated. There will always be people/entities who ignore laws
to seek advantages for their own gains. USG and Private Institutions
should work together to remove bad actors.
Q1c: What are commenters’ views generally with respect to the
liquidity and transparency of the bitcoin markets and the bitcoin
markets’ susceptibility to manipulation?
A1c: After the initial transition, Spot ETFs will significantly reduce
likely occurrence of manipulations and improve transparency. Bitcoin
inherently offers transparency and with the base inflows from large
institutions Bitcoin will level to a stable level driven by supply and
demand very similar to equities/commodities.
Q2: Overall
A2: In the context of manipulations, I believe the Spot Bitcoin will
be significantly larger and less likely to dramatic changes relative
to the Futures movements. Specifically, the Spot Bitcoin will see
investors Holding rather than reacting to same degree of fluctuations
with Futures. Again, in my opinion, Spot or even Futures manipulation
are less likely due to the Use Case; store value
Q3. Overall
A3: I am familiar with technology, and believe the decentralized
architecture and creation of Bitcoin will present unprecedented
challenges for manipulations. Again, there will be those who seek
advantage for themselves however, the collective crypto environment
should allow for more rapid closure through forensic sciences than
with fiat or commodities.
Q4. Overall
A4. In my opinion, Coinbase has dramatically improved its own
governance as well as reacted to changes.requests from the SEC and
others. Adding Coinbase with institutional partners would likely
fortify or harden against any nefarious actors who intend to
manipulate or attempt to incur actions against investors.
Q5: Overall
A5: To the extent there will be some correlations, it is likely to be
no different than spot/futures for other commodities. Of course, this
will apply once the initial settling of inflows to Spot ETFs that will
occur as new long term investors establish their positions.