Mar. 28, 2022
Subject: File No. SR-NYSEArca-2021-90 Dear SEC, I am a small investor from Wisconsin. I’m writing to ask you to reconsider your denial of the conversion of Grayscale Bitcoin Trust (Symbol: GBTC), into a Spot Bitcoin ETF in the United States. I understand the SEC is motivated to protect small investors from market manipulation, but I think approval will reduce artificial manipulation in the BTC market. There are several reasons why this conversion would benefit small investors like me. 1. Currently it is very difficult to invest in Bitcoin inside an IRA. I could move to a small specialty custodian, but I would rather stay with the name-brand custodians like Ameritrade and Schwab, as I believe they are safer. Like most small investors, the majority of my investable money is in my IRA. A spot etf would be a good option for getting BTC exposure. I do realize BTC is volitile and subject to wild swings. But most money managers recommend adding some of this emerging investment vehicle in a diversified portfolio, 2. The SEC has mentioned that a Spot etf is subject to manipulation, but it seems to me the approved Futures etf is guaranteed manipulation. A futures etf is not a very good investment vehicle, especially in the long term. The well-know contango problem means subsequent months on the futures "curve" are priced higher than preceding months. Small investors are guaranteed to lose in a futures etf, and I don't think most small investors could explain "contango" or are aware of how it eats away at gains over time. Given this, I am surprised the SEC was so quick to approve a futures ETF over a spot etf. 3. I currently own a small position in GBTC and it trades at a 27% discount to NAV. If converted, this discount would narrow or be eliminated. This would allow the investment to more closely track the underlying asset. I would think that would be desirable for the SEC if you want to eliminate artificial manipulation. 4. Smart BTC investors will hold for the long term, not trade daily. This will eliminate small price manipulations that may arise if prices are not exact on all markets. Time in the market fixes that. It has been my experience that BTC price is within .001% on various exchanges. Thanks for your consideration of the small investor's perspective. Sincerely, Steve Brielmaier Pewaukee, WI