Subject: “File No. SR-NYSEArca-2021-90” - GBTC and ETHE ETF Conversion
From: Matthew Davis
Affiliation:

Feb. 22, 2022

 


Hello, 


I am writing to request SEC consideration to allow for conversion of both GBTC and ETHE to ETF products. As a retail investor with a long-term investment horizon, I am limited in my ability to access true exposure to the cryptocurrency industry in safe, reliable venues.  


The allowance of conversion to an ETF with redemptions to minimize the discount/premium to NAV for the Grayscale products would provide a safe means to access this exposure. Both products, as you are well aware, are trading at significant discounts to NAV which is hurting investors who previously had no choice but to purchase at a premium due to lack of appropriate means to access spot BTC/ETH exposure in traditional brokerage accounts.  


The mechanics of the current futures ETFs, as you are aware, are far too complex for retail investors to understand and they carry large annual fees to intermediaries due to the nature of the futures contracts.  


Spot BTC/ETH ETFs would solve both previously mentioned issues by allowing redemptions to force parity with NAV and would minimize the amount of fees paid by investors.  


Secondarily, allowing a safe path to exposure would prevent the loss of funds due to preventing the need for less technically-savvy investors from having to self-teach principles of self-custody, blockchain navigation, and avoidance of hacks/scams. This is in the very nature of the SEC's stated purpose, the protection of the common investor.  


Please consider my letter in addition to hundreds of other pleading for this conversion as a definitive statement that allowance for conversion would be aligned with your organization's purpose and in line with the best interests for all investors.  


Thank you for your consideration,  
















Matthew Davis, PharmD 

Infectious Diseases Clinical Specialist 
UCLA Ronald Reagan Medical Center