Subject: File No. SR-NYSEArca-2021-90

Feb. 22, 2022

 


Dear SEC, 
I’m writing to support the conversion of Grayscale Bitcoin Trust (Symbol: GBTC), currently the world’s largest Bitcoin fund, to the first Spot Bitcoin ETF in the United States. 
I am a resident of Florida and wanted to comment on why I believe that the SEC should accept Grayscale’s application to be converted into a spot Bitcoin ETF. The SEC’s job is to protect investors. The current rules are not achieving this goal. GBTC as it currently stands is an inferior investment vehicle compared to a spot ETF. The futures ETF that was approved is much more speculative for investors and reflects a double standard by the SEC, which makes this product a lot riskier. An ETF which is directly connected to the value of the host’s holdings, such as GBTC, would be a much safer investment.   There are numerous ETF’s for gold and silver as well as for other commodities and groups of industrial and tech stocks. Why shouldn’t there be one for Bitcoin? 
GBTC is the easiest and safest way to get Bitcoin exposure, but unfortunately the discount to the NAV is excessive. This would be fixed by a spot ETF, a product that is available to retail investors in other countries. Why not here in the U.S? Authorizing a futures ETF and not a spot one is a great disservice to retail investors. It seems very strange that there is no Spot ETF Bitcoin product in the US. I believe that as the world’s largest Bitcoin fund, GBTC should be approved by the SEC to be an ETF.
Sincerely, 
Tom Baroody