Subject: File No. SR-NYSEArca-2021-90
From: Sam Douglass
Affiliation:

May 28, 2022

Dear US Securities and Exchange Commission, 


I am a young, middle class American interested in diversifying my savings and investments beyond stocks, bonds, and gold. For the young guy like me who is not wealthy and privileged enough to achieve "accredited investor" status, saving and investing is extremely risky and difficult in today's environment. Stocks, even after dropping 20+%, are trading beyond all time highs on many metrics including price to sales and price to earnings. Bonds and treasury bonds are trading at negative real yields, guaranteed to lose me money unless their price appreciates beyond the price I buy them at. Dollars are losing their value due to balance sheet expansion by the treasury and the Federal Reserve which depletes the value of them over time. Gold is difficult and annoying to store, and personally I'd rather not store the value of my savings through it, although I may have to, given the other options are in most cases guaranteed to destroy the value of my savings. 


I have not managed to save up enough yet for a home. It is difficult given that due to the incredibly low interest rates of the past few years, home prices have soared in value during that time. The goal post which I have to hit is moving and receding away from me, no matter how hard I work. And the vehicles of saving to choose from are extremely overpriced as a result of decades of intervention by the federal government in the capital markets. 


Bitcoin gives me a saving grace to this. Given that bitcoin is finite (only 21 million), and secure (backed by the most computing power in the world), I am confident in its ability to serve as a store of my wealth and be my saving grace in this trying time. Now I would like to purchase bitcoin exposure in my Roth IRA account, however there is no option for a bitcoin ETF, so I am forced into riskier options such as BITO (hampered by contango), GBTC (destroys my value due to its inability to keep peg to spot given its a trust and not an ETF), and Microstrategy (buys bitcoin with leverage I'd rather not be exposed to). Please green light the bitcoin ETF and relieve me of having to take on these unnecessary risks. 

I am writing to share with you the needs and motives of regular middle class young men like me, and if your motives truly are to protect the average small guy investor, you would consider my viewpoint, otherwise I would argue that you would be directly opposing your mission, which you state is to "protect investors; maintain fair, orderly, and efficient markets; and facilitate capital formation". Blocking the bitcoin ETF is not protecting me, because it forces me to take riskier investments. It is not fair, because accredited investors and institutions are wealthy enough to afford accountants and tax lawyers to buy bitcoin for them in tax deferred accounts and I cannot. It is not efficient, as GBTC currently sits at a -29.8% discount to NAV at the time of this writing. It does not facilitate capital formation, as it pushes me into less efficient, riskier avenues more likely to lead to destruction of my capital. 


Please consider me and the emails of everyone else writing to you. 


God Bless, 


Sam Douglass