Subject: SR-NYSEArca-2021-90
From: Jim Dall
Affiliation:

Feb. 15, 2022



Regarding GBTC submission for approval as an ETF.
 
I have previously submitted an e mail comment in favor of GBTC being approved as an ETP (ETF), but had two additional comments that were not in my original comments.
 
I think the best comparison for what an investor is looking for with GBTC is GLD ETF.
If I want to purchase gold at the spot price without needing to custody the physical gold and have it be very accurate to the price and backed by the physical asset I can use GLD. 
The same should exist for Bitcoin. Converting GBTC to an ETF would accomplish this objective. It would much more accurately track the spot and reduce arbitrage and increase transparency. 
 
U S clients ought to have better access to Bitcoin ETFs like Canada.
The SEC is significantly behind on this issue and is harming U S investors by not allowing the most accurate and transparent products.
 
Sincerely,
James Dall