Subject: File No. SR-NYSEArca-2021-90
From: Scott Mason
Affiliation:

Mar. 02, 2022

 


Dear Chairman Gensler: 
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. 
We live in an age where new electronic forms of value and exchange are emerging and rapidly becoming broadly accepted. These electronic systems, like Crypto currencies or NFT’s, take many forms, some trying to mimic currency, others mimic commodities like gold, but many are becoming an accepted forms of value exchange and retention.  At the fore front is bitcoin the most widely accepted and adopted as a agreed form of embedded value based on a market agreed price. Bitcoin offers an investor a unique alternative commodity for retention and value trading not unlike gold and other forms of value storage mediums. Uniquely, the cost of ownership of this form of value has the potential to be significantly less then physical asset both in storage and in exchange.
 
I understand the SEC role is to promote a market environment that is worthy of the public's trust and at the same time promote efficient markets to serve the overall good. 
 
The current forms of owning and trading Bitcoin through relatively new exchanges, electronic wallets, and Trusts is both high cost and fraught with risk and complexity that even a sophisticated investor struggles to understand and master. An ETF structure would reduce the inherent cost of owning BTC (note GBTC on 3/3/2022 is trading at a 24% discount to NAV), and allow for more robust tracking of ownership, trading regulation, and simplification in the market transactional processes. I strongly recommend that the SEC provide the regulatory frame work for a BTC based ETF which would address many of these fundamental issues. 
 
More confusing to me was that the SEC chose to allow a futures based bitcoin ETF since this is a far more speculative and risky product to offer to investors. In essence the SEC has legitimized bitcoin but only as a form of speculating (gambling).  I would consider this a greater risk for harm to investors who want to participate in the market then direct ownership in an efficient manner through a ETF. 
 
I request that the SEC move quickly to provide a path for the approval of Grayscale Bitcoin Trust's application before the SEC to convert to a spot ETF. 
 
Sincerely,
 
Scott Mason
 
BSME VPI, MBA Houston, 45 years in business