Subject: SR-NYSEArca-2021-90: WebForm Comments from Shahid Lakha
From: Shahid Lakha
Affiliation: Former Merrill Lynch Financial Consultant Private Accredited Investor

May. 11, 2022

May 11, 2022

 Retail investors, both non-accredited and accredited have been demanding a spot Bitcoin ETF now for years.  We are very familiar with the ETF wrapper.  And a spot ETF solves several problems for us:  1) Many of us do not trust having crypto on an exchange.  As you have already heard by now, Coinbase recently stated that in a potential bankruptcy, depositors would be general unsecured creditors.  That's about the worst thing a depositor / investor wants to hear.  2) Then there are Futures based ETFs, which those of us who have been investors for years don't trust.  There is a lot of slippage as futures roll over, and we all remember how the USO futures-based oil ETF blew up.  3) We also do not want self-custody large amounts of crypto on hardware wallets.  Drives cant be lost.  Passwords can be lost.  And it's very difficult to do estate planning within a self-custody scenario - family members may not be tech savvy amongst many other reasons.  4) Other inefficient fund structures suc
 h as what GBTC currently uses are now trading at significant discount to spot prices, causing substantial losses.  The spot ETF solves ALL of these issues.  We are still going to invest in Bitcoin whether the SEC approves the spot ETF or not.  But all the other investment options are suboptimal to what a spot ETF provides.  And if the SEC really cares about protecting us, then it will approve the spot ETF so that we can avoid suboptimal solutions mentioned above.  But if the SEC rejects the Grayscale ETF, then it becomes very evident that the SEC has ulterior, political motives ahead of investor protections and concerns.  We are telling you in no uncertain terms that we want a spot ETF.  Now will the SEC listen to tax paying citizens?