Subject: File No. SR-NYSEArca-2021-90
From: Cyrille Martin
Affiliation:

May. 06, 2022

 


Hi, 
Please allow GBTC to become an ETF. I like to invest in Bitcoin. It is a new type of asset that allows me to diversify my portfolio, lower its risk and increase the return. 


Right now, I am facing difficulties investing in this asset class and am taking non-necessary risks: 
- Risk of using bitcoin platforms to buy bitcoin: being forced to use multiple exchange platform, which I don't know much about and are not controlled is very risky. The platforms convert my dollars into their crypto dollars, before I can buy and hold Bitcoin. I don't know if these pseudo dollars from crypto platforms are fake and if I will be able to get my money back in real US$ in a few years. 
- Risk on taxes: I want to pay my taxes correctly and I want my taxes to be easy. I prefer to trade with real stock platforms that create real US tax documents that are automatically reported to the government (like Etrade). Instead of me having to create them manually at the end of the year. 
- Risk of being forced to invest in funds that hold bitcoin, but the price of these funds doesn't follow exactly the market price of bitcoin (like GBTC today). And pay expensive costs for that (2% per year). Or in Bitcoin futures, which is just paper and not the real asset. 


Yes, Bitcoin is a volatile asset. 
I think that not having a real ETF that owns the real asset is forcing small investors like me in using even riskier routes. And I don't see the benefits for the US government, as it looks more difficult to verify taxes from trading on platforms like coinbase than Etrade. 


Unknown facts about ETFs: 
I am of course wondering how the market price of Bitcoin will change with an ETF. If everybody start investing in the ETF instead of Bitcoin on current platforms, will the ETF be able to drive the price of bitcoin up and down? I am always wondering if the actual demand of Bitcoin is reflected in the price or if this is manipulated somehow. 
I hope you have people smarter than me at the SEC to answer this :) 


Thank you for your consideration, 


Cyrille Martin (Small investor in GBTC and Bitcoin)