Subject: File No. SR-NYSEArca-2021-90
From: Mark & Wendy Muller
Affiliation:

Feb. 22, 2022

 


  
Dear SEC, 

I am 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 think your arguments for not allowing this to become an ETF is a poorly thought out decision.  Here is why: 
  
1)  Investors like me are being hurt as the Bitcoin Trust is trading at a 30-35+% discount to fair value.  You are causing great harm to investors.  Your job is to protect investors, not hurt them.  Your decision to not allow this (while favoring an far inferior product with the futures bitcoin etfs) is costing investors BILLIONS of dollars right now.  That is a huge impact of damage that you have allowed to fester that far outweighs any minor concerns you may have.  There are very few decisions you can make that can immediately impact man thousands of investors 
  
2)  The Futures ETF's are not tracking the returns as well as the spot bitcoin prices.  I - and any investor large or small - would prefer to have a spot etf, as it would track the price over time far more accurately than the Future's etf.  There is way too much slippage on the future's etf.  The futures market can just as easily be manipulated as the spot market (maybe more so with such high leverage).  Once again you are hurting investors, not protecting them.  
  
3)  When I look at the various etf's that have been approved, the bitcoin etf is much less risky than some of the exotic etf's you have already approved ( ie leveraged indexes of all shapes and sizes that often return -90+% over time, niche indexes full of speculative stocks, etc).  
  
4)  Our market's should be regulated, but open....  and regulations should be made with the investors best interests at heart.  Right now, harm is being caused to investors such as myself.  Please consider allowing this trust to become converted to an ETF.  It is the largest bitcoin fund with a history of safekeeping of assets.  It will be the best etf available to track the actual asset.  Converting it to an ETF will PROTECT investors such as myself from the fund trading at extreme discounts to the actual value, and will have superior tracking of the asset over time...  which the futures etf's are already failing miserably at.  

Sincerely, 

Mark Muller 
A concerned investor who wants investors to be protected & relieved from unnecessary losses, and save investors hundreds of millions of dollars, and possibly billions over time, in unneccessary slippage from Future's etf's.