Public Comments on Rule Change Re: Trading Shares of SolidX Bitcoin Trust

December 1, 2016 • Public Comments

Dear Mr. Fields:

Thank you for the opportunity to comment on the proposed rule change by NYSE Acra, Inc., relating to the listing and trading of shares of the SolidX Bitcoin Trust.

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As the Commission is aware, bitcoin and other innovations known as “cryptocurrencies” have risen from philosophical experiments to novel forces within the world’s economy. Among the many new cryptocurrencies, bitcoin has become the established leader. Since its creation in 2008 the price of one bitcoin has increased from $0.08 to approximately $730. Many investors may be interested in gaining exposure to bitcoin but may lack the expertise and technology to store their bitcoin securely. An ETF would efficiently allocate the cost of transferring and storing the bitcoin, allowing investors to have the benefits of ownership while sharing the risk of loss through hacking or other technological failures.

Furthermore, to the extent that the SEC believes the federal securities regulatory regime promotes investor protection, it should welcome the introduction of products like the proposed ETF and any other that offer similar features. By offering bitcoin exposure through a publicly traded security, an ETF like SolidX Bitcoin Trust would provide investors with the same protections they receive when buying any other publicly traded security. In addition to whatever protection the federal law provides, investors would also benefit from diversifying their portfolio through the addition of the leading cryptocurrency.

I believe that approving the rule change would ultimately promote investor protection, and would therefore forward the mission of the SEC. I hope that the Commission will consider the opportunity that the proposed ETF and other similar funds would present for investors. Thank you again for your attention to these comments.

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