Subject: Response to “File No. SR-NYSEArca-2021-90”
From: Joseph Hwang
Affiliation:

Mar. 04, 2022

 


I would like to express support for a spot bitcoin ETF as a means to protect investors against the inferior bitcoin linked products available in the market today. 


While investors can purchase GBTC or one of the futures based bitcoin ETFs, those products result in significant risks to the consumer than a direct spot bitcoin ETF would. Both GBTC and futures based ETFs have significant tracking error resulting in potentially inferior returns for consumers. Particularly with futures based ETFs, contango results in meaningfully reduced returns over time relative to the returns of holding actual bitcoin, thereby resulting in harm to the consumer, see links below on tracking error:https://www.risk.net/investing/7805731/the-worlds-largest-bitcoin-fund-has-a-tracking-error-problem 
GBTC tracking error - https://www.risk.net/investing/7805731/the-worlds-largest-bitcoin-fund-has-a-tracking-error-problem Futures based ETF tracking error - https://www.coindesk.com/markets/2021/10/20/bitcoin-etfs-arent-new-heres-how-theyve-fared-outside-the-us/ There are many reasons why investors, both retail and institutional, are unable to hold bitcoin directly. GBTC and futures based ETFs harm rather than help consumers as a result of the aforementioned tracking errors. A spot bitcoin ETF would significantly improve consumer protection 



While the SEC has previously expressed concerns about the safety of a spot bitcoin ETF, other nations, such as Canada, Brazil, and Singapore have approved spot bitcoin ETF. I have the utmost faith that the SEC is more than up to the challenge of catching up, rather than falling behind, in protecting US consumers by also approving a spot bitcoin ETF 


Thank you 

Joseph Hwang