Subject: File # SR-NYSEArca-2021-90
From: Benjamin Gehlman
Affiliation:

Nov. 06, 2021



I am an individual investor who has been holding GBTC shares for greater than one year. In this time frame, numerous bitcoin ETFs have been approved in other countries, and GBTC has gone from trading at a premium to trading at a significant discount. This discount was deepened when the SEC approved bitcoin futures ETF and not spot bitcoin ETFs. If the goal of the SEC is to protect investors, I would posit that the SEC is failing to protect the investors in GBTC, a 40 billion dollar trust that voluntarily reports to the SEC. It was detrimental to approve futures and not spot btc ETFs, and btc spot ETFs have been denied in the past because the SEC claimed that there were already ways to gain btc exposure in funds such as GBTC. A fund that varies from a 30% premium to a 20% discount fails to accurately track the spot price, and this issue could easily be solved by allowing GBTC to convert to a spot ETF. Finally, other ETFs I own have sold their GBTC shares and replaced them with the Canadian spot btc ETFs. Ergo, the SEC is inadvertently forcing individuals and institutions to look to spot btc products in Canada, Brazil, Europe and Australia to gain access to regulated ETFs that accurately track btc. Please allow GBTC to convert ASAP in the name of investor protection, and do not allow other bitcoin spot ETFs to begin trading before GBTC to protect the 40 billion in AUM from further harm.