Subject: File No. SR-NYSEArca-2021-90 - GBTC Investor Comment
From: Steven Venino
Affiliation:

Feb. 22, 2022

 


To whom it may concern: 


I am writing requesting - urging - that you allow for the conversion of the Grayscale Bitcoin Trust into an ETF as soon as possible. I have worked on Wall Street and am now an investor in the world of digital assets; during my time on Wall Street, I helped run an ETF desk and am aware of the in's and out's and considerations all around of this subject. I have perspectives from both ends of the field.  


There is no possible way to justify not approving the ETF conversion -- further, it is totally absurd to approve the futures-based ETF and not spot. In doing so, rather than protecting retail investors, you are hurting them in two clear ways: 1.) the roll cost of futures is a massive expense and one 99% of retail will never have an idea of (just look at the USO oil ETF v. spot oil...a complete joke) & 2.) those invested in GBTC are being absolutely gutted by the discount. It is understood that these are risks one should be aware of prior to making an investment, but it is still a worthwhile consideration considering how many have invested in the fund (many under the premise that their regulators would make the rational decision to eventually allow the conversion to take place). This is truly despicable all around. 


There are plenty of secure custody options on the market, which means that aspect of the fund logistics should not be a hurdle to approval. I urge you to hear the voice of the people and allow for the conversion -- there is an incredible amount of undue harm being inflicted on retail investors under the guise of your intentions to "protect them".  




Sincerely, 
Steven P. Veninio