Subject: File No. SR-NYSEArca-2021-90
From: Michael Stroup
Affiliation:

Mar. 28, 2022

 



To the SEC, 


Please allow GBTC to become an ETF. 


1) There are hundreds of thousands of normal American investors in GBTC. I am one of them via my IRA. I view investing in Bitcoin similar to investing in any other promising high growth tech startup. Vehicles like GBTC make it easy to invest in something like Bitcoin with a normal IRA account. I have saved perhaps hundreds of hours of time by investing in GBTC and not learning how to run a node or perform custody. By investing through my normal IRA it is very easy for me to analyze my asset allocation and diversification. 


2) However, right now I have lost about 30% on my investment because GBTC is trading at a discount to net asset value. If GBTC were an ETF, large financial institutions could perform an arbitrage with the shares that would increase the price closer to net asset value. By converting GBTC to an ETF, the SEC would go a long way to helping protect me as an investor. 


3) A Bitcoin ETF with real Bitcoin rather than futures would be a better fit for the average American investor. The futures based ETF is harmful for long term investors due to the cost of rolling futures and tracking error. 


4) I don't understand why the SEC has approved ETFs that are extremely harmful to average investors. Many of the 3x leveraged ETFs or VIX ETFs are guaranteed to lose you money over time. It is absolute insanity that these investments exist but a physical Bitcoin ETF doesn't exist. 


Please allow Bitcoin to become an ETF. 


Thank you, 
Michael Stroup