Subject: File No. SR-NYSEArca-2021-90
From: Mark Engelberg
Affiliation:

Mar. 11, 2022

 



I am writing to express my support for the SEC to approve the conversion of Grayscale's GBTC to an ETF. 

As a programmer, I fully understand how Bitcoin works and what a landmark technology it is. As an investor, I understand the risks associated with Bitcoin, and the tradeoffs associated with holding it directly, as opposed to using a custodian. 


GBTC currently is the only way to invest in Bitcoin through brokerage platforms like Vanguard, making it one of the most convenient ways to get exposure to Bitcoin in an IRA. Unfortunately, GBTC is inherently inefficient, with high fees and a premium to NAV (currently negative). 


Grayscale wants to convert GBTC to an ETF to make it a better product, with lower management fees and a trade value that better reflects the underlying asset. The risks remain the same, it's simply better for investors. For that reason, the SEC absolutely should approve the conversion to an ETF. 


Other countries have successfully approved Bitcoin ETFs; I am tired of seeing other countries get ahead. The United States should be a leader in this space. Also, products like GBTC tend to only be available to the very wealthy, which seems rather unfair; a Bitcoin ETF helps fix this. 


I have read the SEC's reasons for denying previous Bitcoin ETFs; the reasoning is outdated and no longer makes sense. The conversion should be approved. 


Mark Engelberg