Subject: Comments for File No. SR-NYSEArca-2021-90
From: Michael Rudinsky
Affiliation:

May. 05, 2022

 



Hi SEC comments:
I am an owner of GBTC shares in both Etrade and TD Ameritrade, for both taxable and retirement (roth, normal Ira) accounts.

I bought GBTC (and the Ethereum Grayscale equivalent) for a number of reasons: ease of purchase, and to reduce the risk and reporting hassle of self-custody in “out of the financial system” accounts.
I now realize that I have purchased a faulty financial product aimed at Wall Street profits and ownership timing arbitrage via the Premium/Discount system. In effect it is allowing Wall Street level investors to mine the small investors for profits, when compared to buying outright bitcoins.
Had I bought outright bitcoins, I would have avoided the discount/premium problems in addition to leaving the financial system that is not geared to providing fair service to me. It should be noted that the SEC has approved this Grayscale product, knowing this product is not beneficial to the small investor.

If the financial system you are chartered to manage was managed correctly, you would have not allowed GBTC and closed end funds like them to be released.
But furthermore, the SEC is compounding earlier errors by not allowing the investing field to be leveled. if you been performing your charter now, you would also, immediately, approve a spot price based ETF to balance out the advantages to larger, institutional investors that the Futures ETF provide. By not performing your oversite job, you are not only locking in the advantage Wall Street level investors have via early use of the GBTC like products, but you are also benefiting Wall Street in the advantage via only allowing the Futures ETF.

You are in effect, forcing investors like me to leave “your financial system” to rely on self-custody and governance outside of “your financial system”. I will be forced to take losses (caused by the discount) but am willing to do so because I am forced to admit that “your financial system” is not fair to the little investor, and will never be fair to the little, individual investor. The SEC has not worked for the little investor and by not approving vehicles like the bitcoin ETF is not working for the benefit of the little investor.

Thanks