Subject: File No. SR-NYSEArca-2021-90
From: Dennis Burgess
Affiliation:

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 CPA entering my 48th tax season.  I have seen crazy tax laws passed over my years to manipulate the economy or invoke a political position.  This is what the SEC is now doing by approving a Bitcoin futures ETF but not a spot ETF.  The futures market has a much larger gambling aspect to it than buying a spot ETF as time is also a factor in the investment.  I am reminded of the adage not to invest in what you do not understand.  The futures market is for the professional traders and not the small guy!   
In 2017, the CEO of one of the 4 largest CPA firms in the world made the statement that blockchain is going to change the business world.  I knew at the time that the CEO of a global CPA firm was much more knowledgeable than I in this new technology.  Even though I am reminded not to invest what you do not understand, I have the full faith and confidence in the CEO of a global CPA firm.  If I am going to invest, a spot ETF would remove the risk of ownership in Bitcoin much like buying a spot precious metals ETF would remove the risk of ownership of buying the actual metals.  I have faith in the technological abilities of Grayscale much like I have the faith in the wisdom of the CEO of a global CPA firm.     
I have discussed Bitcoin and the related blockchain technology with many clients to inform them of this future technology.  I have also explained the premiums and discounts associated with the Grayscale Bitcoin investment.  However, the SEC has caused the small investor to remain on the sidelines of a coming technology that is going to change the world or to take more risks than would otherwise be advisable.  While supposedly being a protector of the small investor, in this instance, the SEC is providing a huge disservice to the segment of the investment community they were formed to protect. 
Please remove the risk of the futures market, the risk of ownership, and the risk of great price discounts by allowing the small investor to participate in the future through a Grayscale Bitcoin spot ETF. 
Thank you, 
Dennis D Burgess, CPA