Subject: File No. SR-NYSEArca-2021-90
From: Axia Antar
Affiliation:

Mar. 22, 2022

 


Hi, 


I'd like SEC approval for GBTC to be converted to an ETF for the following reasons 


1. We deserve a spot BTC ETF. Other countries have such products already. Not having a spot BTC ETF puts American investors at a disadvantage. 
2. Unlike 'paper' products like Gold, 'physical' clearance of BTC is possible, efficient and verifiable. 
3. Market mechanisms to bridge the difference between GBTC NAV and spot BTC price exist. 
4. BTC futures ETFs are an inappropriate vehicle for retail investors. Most futures ET Products have a built-in decay that results in long term losses due to futures rollovers. 
5. Approval for spot BTC products would likely eliminate the discount between GBTC NAV and the value implied by the spot price of BTC. It would also likely introduce competition in the market for spot BTC products and consequently reduce the fee paid on such products which are presently prohibitive. 


If the SEC is serious about protecting investors, especially retail investors, they would approve a spot BTC product right away. 


Regards, 
Antaraxia