Subject: File No. SR-NYSE-Arca-2021-90
From: Hal Davis
Affiliation:

Feb. 22, 2022

 


To whom it may concern, 


Please accept my comments supporting the approval of a spot ETF backed by the underlying Bitcoin asset, specifically the conversion of the Grayscale Bitcoin Trust to an ETF. 


This will provide an avenue for investors to gain Bitcoin exposure through traditional finance channels who otherwise may not be comfortable holding and maintaining self-custody themselves. Many investors are not comfortable with the Bitcoin rails, but are very comfortable using a traditional broker. This is preventing US investors while investors in other countries are able to gain spot exposure to Bitcoin through local Spot Bitcoin ETFs.  In the current environment of high inflation, elevated real estate valuations, tumultuous stock market, and bond market facing rising rates, opening the Bitcoin asset class to US investors fits the bill of protecting investors.  


Converting the Trust to an ETF also checks the box for fair, orderly, and efficient markets considering the reduction of premium/discount to NAV. Further, the direct exposure to Bitcoin through the ETF eliminates the contango and backwardation present in the Bitcoin futures ETFs.  It is time to allow a spot ETF as the superior investment vehicle for individual and corporate investors. This should no longer be restricted by the SEC. 


Thank you for your consideration, 
Hal Davis