Subject: File No. SR-NYSEArca-2021-90
From: Geoff Dudgeon
Affiliation:

Mar. 14, 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. 

Far more important than the above conversion is the need for the SEC to allow spot bitcoin ETF products to come to market. Adoption of this asset will continue to grow, and failing to allow for a proper spot ETF will result in investor harm: either through needlessly burdensome roll costs (via futures ETFs), or by driving investors away from safe, regulated ETF venues to other vehicles which present more custody and/or counterparty risk. 


The SEC in allowing the launch of futures-based ETFs has taken a long overdue first step; but this is a half measure. Please complete the work and allow the launch of spot bitcoin ETFs -- either the above referenced GBTC conversion, or those put forward by other issuers. 

Sincerely, 
Geoff Dudgeon