Subject: File No. SR-NYSEArca-2021-90

Mar. 09, 2022

 


Dear SEC, 
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. 
The SEC approved the Bitcoin Futures ETF last fall, a cash-settled product where custody of the actual Bitcoin is never obtained, and it is perplexing that a futures ETF would be approved prior to, or in lieu of, a spot Bitcoin ETF product.  The Bitcoin futures ETF is not a good product for the small retail investor, whom the SEC vows to protect.  Due to the inherent contango in futures markets, bitcoin included, investors will earn dramatically lower returns than owning the bitcoin directly through a CryptoCurreny exchange such as Coinbase.  Furthermore, the small retail investor does not possess the financial resources of knowledge to trade futures contracts. 
I do not wish to get in a detailed explanation of contango and how the Bitcoin Futures ETF hurts small retail investors as I am sure the good folks at the SEC are well aware of the issues posed by futures based products such as ETF’s and ETN’s.  Instead, I would like to point out the fact that the SEC has long ago approved a spot gold product in the SPDR Gold Shares (GLD) ETF.  Gold is a physical store of value and Bitcoin is a digital store of value and converting the Grayscale Bitcoin Trust into a spot Bitcoin ETF product would make it accessible to the small retail investor in the same manner in which Gold has become more easily accessible through the GLD product.  
On behalf of myself and all the other small retail investors like myself I respectfully request that the SEC approves the conversion of the Grayscale Bitcoin Trust to the first Spot Bitcoin ETF in the United States of America.
Kind Regards, 


John Shinas