Feb. 22, 2022
Dear Chair Gensler, I write to you to express my strong advocacy for the SEC's approval of a spot Bitcoin ETF. I believe that a spot ETF is a much better form of investment for the average investor than the current futures ETF version for the following reasons: 1) A spot ETF is much less complicated to understand and therefore much easier for the average investor to assess the risk of the underlying investment => BTC goes up my investment in the ETF goes up almost penny for penny (excluding very low fees of 50bps or less) 2) By approving GBTC's spot ETF application the premium/discount issue is eliminated and again makes it simpler and less risky for the average investor. 3) BY approving GBTC's application first it allows the largest (650k BTC) and most experienced Bitcoin related investment manager with a long track record of responsible custodianship to set the standard in demonstrating what best in industry practices look like Thank you for considering my comments on this issue. Sincerely, Frank Doyle Professor of Finance (part-time)