Subject: File No. SR-NYSEArca-2021-90
From: Ross Kaminsky
Affiliation:

Feb. 22, 2022

 


Dear SEC, 
As a long-time trader, investor, and approved member of multiple US financial market exchanges (including CBOE and CBOT), I would like to encourage you to allow the Grayscale Bitcoin Trust (GBTC) to convert to an ETF. 
First, there is no legitimate important difference from a regulatory perspective between holding the underlying “coin” and holding futures based on the coin yet products which hold the futures have been granted ETF status.
Second, maintaining the current status does harm to investors by allowing, even causing, the product to trade at values wildly different from the underlying Net Asset Value.
I realize that the SEC has other concerns about cryptocurrencies but those need not be addressed by preventing this product from converting to an ETF.
Sincerely, 
Ross G Kaminsky