Subject: File No. SR-NYSEArca-2021-90
From: Ryan Thompson
Affiliation:

Feb. 22, 2022

 


Dear SEC, 

I’m a resident of Washington 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. 


Here are a few reasons why I support the approval:  



1. A spot bitcoin ETF offers superior investor protection when compared to the existing alternatives:  
The GBTC fund, as currently structured, creates price dislocations via a premium or discount to Net Asset Value (NAV). Over the last two years, bitcoin appreciated +283% in value, but the GBTC fund only appreciated +119% in value due to the limitations of the fund structure where a +41% premium to NAV compressed to a -20% discount to NAV. A spot ETF would have resulted in investors making +164% more return in the last two years. Please don't "protect" me from an incremental +164% in returns, I'd preferred to have made this in my Roth IRA, not lost it. The only way to hold BTC there was through GBTC, a spot ETF fixes this.  Futures ETFs lose value over time due to expensive monthly futures contracts. You just approved Futures ETFs which are literally designed for institutional investors to trade short term. They are the least helpful thing you could approve for retail investors who are trying to execute a simple/manageable buy and hold strategy for the long term. Please don't "protect" retail investors by allowing them to get front-run by institutions.   Direct BTC exposure that requires development of technical skills to buy and hold the bitcoin as a bearer asset is exclusionary to non-technical investors. Investors 65 and older hold almost 50% of the value of the U.S. stock market. While some of these investors are digitally and technically capable, many of them lack the resources or desire to learn how to take self-custody of private keys and gain direct exposure to bitcoin. Allowing them to gain exposure through their traditional vehicles with existing brokerage accounts, provides them with more options to diversify their hard earned money. Please don't "protect" non-digital, non-technical investors from making a choice to diversify their portfolios into the best performing asset of the last 10 years. Beyond non-technical investors, the broader investor class with $37.2T of value locked up in retirement accounts deserves the option to invest their money into diversified asset classes such as bitcoin through structures that don't significantly underperform the underlying asset.  
2. The approval and existence of the alternatives, especially a futures based ETF, is logically inconsistent with the denial of a spot ETF. Funds and futures that are allowed correlate directly with the spot price, with only one difference: the currently allowed funds and futures lose value over time relative to the not allowed spot. Please don't "protect" me from better performance. 


3. Other major countries are doing this, the USA will lose its competitive edge. Please don't "protect" the U.S. from leading in innovation and competition. 


4. Other ETFs with far higher risk to investors, like triple leveraged short equity ETF's are approved all the time. If you're actually going to honestly try and "protect" investors, then do your job and actually protect them from garbage products like triple leveraged Nasdaq shorts, where if you put $100 in it 10 years ago you'd have lost 95% of your money.  Other investment options such as naked shorts, or trading with leverage, or call options, are all far riskier for investors than a simple spot bitcoin ETF.  


5. People are freely able to lose all of their money at a casino in one night, buy lottery tickets sold and marketed by the gov't, or in any number of other creative ways squander their wealth. Please don't "protect" people from more wisely investing their money in a digital store of value that is the best performing asset for the last 10 years.  


Bitcoin is hope for small investors who want to store the value of their hard earned labor. Please do not continue choosing to protect wall street at the expense of main street, and please do not disingenuously do this all the while saying its for the protection of main street. Please don't shaft us, but if you're gonna shaft us just say it. 



Sincerely, 
  
Ryan Thompson