Dec. 20, 2019
Hi, Re: File No. SR-NYSEArca-2019-39; Notice of Filing of Proposed Rule Change to Amend NYSE Arca Rule 8.201-E (Commodity-Based Trust Shares) and to List and Trade Shares of the United States Bitcoin and Treasury Investment Trust under NYSE Arca Rule 8.201-E I would like to comment that cryptocurrencies are speculative assets, not investments. They are not relevant to investors, and it is not clear that they ever will be. It is not helpful for providers to be using ETPs to facilitate exposure to purely speculative risk classes, simply because demand currently exists. An asset or a risk class does not become investible simply because the market has attached a price to it, because investment is fundamentally about value. Without a linkage, however tenuous, to future cash flows or economic production, a risk class is necessarily relegated to the realms of speculation. ETP providers, and the exchanges on which they launch, should limit their scope to providing real investors with the tools to acquire and manage value. Many Thanks, A.Holdsworth