Mar. 28, 2022
Monday March 28, 2022 Vanessa Countryman, Secretary Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-0609 Via: rule-comments@sec.gov Subject: File Number: SR-NYSEArca-2021-90 SEC: As a holder of Grayscale Bitcoin Trust, I wanted to offer the following comments. Please regulate crypto currencies and allow spot ETFs. My investment is a store of value as an alternative to holding United States dollars, which has been devalued by 96% since 1913. In August of last year Chair Gary Gensler, stated “Further, it [crypto assets and blockchain technology] has been and could continue to be a catalyst for change in the fields of finance and money.” Based upon that it sounds as of he is resigned to that fact that it shouldn’t get regulated out of existence. Chair Gensler went on to say, “Right now, we just don’t have enough investor protection in crypto. Frankly, at this time, it’s more like the Wild West.” Later he said, “At the heart of finance is trust. And at the heart of trust in markets is investor protection. If this field is going to continue, or reach any of its potential to be a catalyst for change, we better bring it into public policy frameworks.” As a former Asset management executive, I’m all for that. So what are you waiting for? I dont' care if you call crypto currencies a security, a currency, a commodity, a store of value, unit of account, or medium of exchange. Just get on with it and regulate it however you want. The longer you wait the more established and entrenched the investing public becomes, making your regulation that more disruptive. Personally I would trust Grayscale Bitcoin Trust better if it was readily convertible into actual Bitcoin, such as how ETFs function so commonly in the market today. In its present form Grayscale themselves says, “Grayscale, as sponsor of each Trust and the manager of the Fund, has total authority over the Trusts and the Fund and shareholders’ rights are extremely limited”. Wow! As an ETF, more disclosure, more regulation and convertibility would help protect me from the unforeseen. Sincerely, John E. Sundeen Jr., CFA