Subject: SR-NYSEArca-2021-90
From: David McBane
Affiliation:

Feb. 15, 2022



As an investor that's held GBTC in my Roth IRA since 2018, I understand the risks of a closed-end fund, and have experienced both price premiums and discounts to NAV during my investment in GBTC. As the worlds largest fund containing Bitcoin, As an investor - someone the SEC is \"supposed to be protecting\", can you explain to me how incessantly rejecting spot Bitcoin ETF's is good for me? And In this particular instance, can you explain how it protects me?

Past rejections speak to: manipulation, liquidity and transparency.
Manipulation - is allowing sophisticated/wall street to play the arb trade while milking the "little guy" you are supposed to be protecting.
Liquidity - come on, bitcoin is the most liquid market in the world, trading 24/7 365.  Billions of dollars trade everyday.
Transparency - Bitcoin is way more visible than shady banks that pay hundreds of billions of dollars in fines for illegal activity manipulating the precious metals markets or leveraging into shady markets for profit.  Bitcoin's ledger is transparent.  In fact, the FBI has voiced that they like crimes that are committed using Bitcoin since they can track it easier.  Before you get on your high horse, don't forget, the most crime in the world is conducted using US dollars.

It's time the SEC stops \"protecting\" investors, and starts ALLOWING investors NAV access to the UNDERLYING. It's pathetic that Canada and now Europe is ahead of the USA in this regard. The only thing the SEC is protecting is the CME Group's bottom line and wall street.
How are you protecting ME - an average citizen - with your decisions? Or are your decisions aimed at protecting the major institutions that don't wish to see Bitcoin become a household name? How are you protecting the thousands of investors that bought GBTC at a premium?
Look - I understand and understood the risk of a closed-end fund not trading at NAV. But let's be real - the SEC has no interest in \"protecting investors\". If the SEC had ANY interest in protecting investors, it would SURELY allow the largest institutional holder of Bitcoin in the WORLD to convert it's closed-end fund currently trading at a 25% discount into an open-ended ETF and allow it's holders to at LEAST be able to sell for the Net Asset Value. Explain to me how NOT allowing this is \"protecting me\"

Do better Gary Gensler and the SEC.  Try looking out for the average American for once.  Talk about a loss of faith in the govt.