Subject: File No. SR-NYSEArca-2021-90
From: Robert Conrad
Affiliation:

Feb. 22, 2022

 


GBTC should be approved as an ETP (ETF). The change would greatly improve the transparency of the product and allow investors more direct access to bitcoin at a price that reflects the market price of bitcoin.  An ETF would provide easier and less expensive access than other options like a bitcoin wallet.
The fact that there is an approved bitcoin ETF that uses derivatives only supports the approval of a spot ETP. By any measure a derivatives product is more complex and if investors can handle that than they can certainly understand and handle a spot based product. Spot ETF's are also approved in other countries with no adverse consequences.
Investors are looking for a straightforward access to bitcoin and other crypto currencies and upgrading GBTC to an ETF would accomplish this objective.