Subject: File No. SR-NYSEArca-2021-90
From: Keith Rothberg
Affiliation:

Feb. 23, 2022



To whom this may concern:

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 currently own GBTC and ETHE shares.

There should be little doubt that the crypto-train has left the station.  I’ve heard arguments hindering the adoption of an ETF based on bitcoin’s volatility, yet the SEC has approved leveraged ETF’s that are wildly volatile, ie, SOXL and  JNUG.  Check out what JNUG did in the three week period from February 22 thru March 14, 2020.

The transition to an ETF status would raise the price to be on par with its NAV.  Many (hundreds? thousands?) of cryptos are junk, but bitcoin and Ethereum are not and they are on a path to becoming mainstream.  From an IRS perspective, the tax consequences for generating revenue is potentially huge.

I believe that conversion to ETF designation is warranted and overdue at this point.  Thank you.


Sincerely,

keith rothberg