Subject: File No. SR-NYSEArca-2021-90
From: Noah Ruderman
Affiliation:

Feb. 26, 2022

 





To whom it may concern, 


I am writing to voice my support for the immediate approval of a Bitcoin spot ETF. 

The SEC's mandate is "protect investors; maintain fair, orderly, and efficient markets; and facilitate capital formation". The failure of the SEC to approve a Bitcoin spot ETF has hurt investors as well as created chaotic and inefficient markets. Bitcoin trusts such as GBTC, the most popular way to get Bitcoin exposure via a brokerage account, are trading at historic negative premiums (up to -30%) because there is no redemption mechanism. This harm is a direct consequence of the SEC not approving the conversion of Bitcoin trusts to spot ETFs. I fail to see exactly what the SEC is trying to protect retail investors from which is less harmful than an indefinite, growing, historic, negative premium on the most popular asset to gain Bitcoin exposure. 


Retail investors want access to Bitcoin in their brokerage accounts. They will buy Bitcoin-backed assets regardless of whether the SEC approves a spot ETF or not. But without a spot ETF, they will be forced to buy substandard assets that inefficiently track the real price of Bitcoin. The harm caused by poorly tracking the price of a major asset indefinitely far outweighs whatever harm the SEC is trying to protect investors from. 


I think the SEC should consider that regulatory inaction can harm investors, and more carefully consider their mission of protecting investors. 


Noah Ruderman