Feb. 22, 2022
To Whom It May Concern: Please consider approving a spot BTC ETF, such as GBTC. Futures ETFs are an inferior product for unsophisticated investors. Bitcoin futures trade in contango so the fund experiences roll decay. In the roughly four months since BITO started trading, that decay was roughly 3% (12% annualized if it remains constant). That's a big tax on retail investors. A spot ETF is needed in order to avoid retail investor harm. Yes cryptocurrency prices are illiquid and vary in pricing globally, but the means by which Grayscale proposes to use an index is no different from the reference rate used to determine CME futures' fair value and in turn the value of futures ETFs NAV (BITO). Additionally, we've seen that variations in Bitcoin pricing do not last long due to arbitrage. It is time for a spot Bitcoin fund in order to not tax unaware retail investors, and for holders of GBTC to have their 2% management fee reduced. Best, Landon Arnold