Subject: File No. SR-NYSEArca-2021-90
From: Bruce Gutkin
Affiliation:

Apr. 07, 2022

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Dear SEC,

The SEC has moved slowly to approve a bitcoin ETF. I am sympathetic why, but today 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, as well as the approval of other bitcoin spot ETFs.

Thus far, the SEC’s inclusion of futures based bitcoin ETFs locks investors into an attriting asset; the monthly futures roll degrades investor capital over time. Since CME futures are ineluctably intertwined to the price of the underlying bitcoin, approving spot bitcoin ETFs will protect investors against the unnecessary cost associated with that monthly roll. Further, multi-sig custody solutions offer regulation-free assurance that the ETFs assets are protected.


Sincerely,
Bruce Gutkin
Economic Autonomy LLC