Subject: File No. SR-NYSEArca-2021-90
From: Jason Papier
Affiliation:

Feb. 22, 2022



Hello,

I’m a financial planner in favor of converting the Bitcoin Trust (GBTC) to an ETF.

Clients are purchasing Bitcoin, either direct, via private funds, or through this trust.  This will continue to happen until there is an ETF, simply because their is demand for tracking the price of Bitcoin.  There is much less demand for actually using Bitcoin for commerce.

Buying direct has major security issues, both for the client and for our country.  The client can lose their money due to theft or negligence.  And as we know, it can also be hard for governments to track, reducing tax collection and enabling a black market.

Purchased through a private fund, investors need to have a minimum net worth/income, by law.  This means some people are shut out while others have access.  The funds are also expensive due to their smaller size and the costs of running such a fund with low assets.  Finally, they charge more based on a client’s desire for professional management and the lack of other options.  All of these result in a product that is not consumer friendly.

Using the Bitcoin Trust has become the choice with the lowest downside for most clients.  And it’s $25b+ in assets proves the high demand.  However, Grayscale is able to charge 2%, which is exorbitant by ETF standards. This means consumers are losing money due to the structure and lack of competition.

Converting to an ETF would enable consumers to skip buying direct.  That would allow a bright line to be drawn between investors and those using Bitcoin for other purposes.  (Not to mention making tax collecting much easier.)  It would provide accurate pricing and access for everyone.  And it would lower costs for investors, which would result in hundreds of millions of dollars saved.

With this in mind, I urge you to allow the conversion of GBTC to an ETF.

Sincerely,

Jason


Jason Papier

Managing Member
Werba Rubin Papier Wealth Management