Subject: File No. SR-NYSEArca-2021-90
From: Manu Oberoi
Affiliation:

Feb. 27, 2022

 

Dear SEC, 

I’m writing to support the conversion of Grayscale Bitcoin Trust (Symbol: GBTC), currently the world’s largest Bitcoin fund, to the first Spot Bitcoin ETF in the United States. 

I am a real estate broker based out of Massachusetts. I was first introduced to bitcoin in December 2013 when I read an article in the Wall Street Journal. Since then, I have read up about the developments in the bitcoin space on a daily basis and have been fascinated by it's evolution. My motivation for writing to you is not because I want the bitcoin price to increase. The price has increased thousands of percent since I first purchased it without the help of a spot bitcoin ETF approval. The reason I am writing to you is that I would like a safer vehicle to store my bitcoin assets and I would like the public in large including my friends and family to have access to a safe vehicle to do so as well.  

Currently, the choices people have when it comes to investing in bitcoin have major flaws. I see it akin to having to use a hacksaw or axe in order to spread butter on my toast. Popular methods of investing are currently more expensive, dangerous, and opaque than what a SEC regulated spot ETF would be. The most popular vehicle to invest through is crypto exchanges. Even if people find an exchange with low fees to purchase bitcoin, they always run into the risk of the exchange being hacked. Another popular choice is when people store their bitcoin in cold storage, such as hardware wallets and paper wallets. While taking self custody of bitcoin can be seen as a great way to store bitcoin for some people, it is usually full of dangers for most people. Cold custody bitcoin can be easily lost, stolen, forgotten, and is often not successfully transferred to heirs if the holder passes away. An option that has recently become popular has been to invest in companies that have put bitcoin on their balance sheet, such as Tesla, MicroStrategy, publicly traded bitcoin miners etc. Investors in this categories risk their investments losing value because of external factors such as mismanagement of the company, words or actions taken by company executives that negatively affect share price, and negative impacts of the core business of the company not related to bitcoin itself. The Grayscale bitcoin trust while seemingly a good option, is expensive and has the risk of trading at a premium or discount, making it far less than ideal. Another option although not very popular yet, is to find a brokerage that will allow you to purchase international spot bitcoin ETF's. Such brokerages are few and far between, and international ETF's do not give the same level of comfort as an SEC regulated ETF. Lastly, there are thousands of people who use self directed IRA's through companies that could be hacked and/or have outrageous fees. I'm not even going to get into a discussion of a futures ETF since nobody I know has ever invested in one and from my research seems like a very expensive way to invest. A SEC regulated spot bitcoin ETF would give investors, savers, speculators, and anyone else currently invested in the space or thinking about entering the space to use an efficient and safe vehicle. 

This is my first letter to you even though I could have written to you years ago when the first spot bitcoin ETF application was filed. Why am I writing to you now? It's because now that tens of millions of Americans have and are invested in bitcoin, it is more important than it has ever been to have a safe vehicle that we can all use. While bitcoin is currently volatile, speculative, and relatively new, so are numerous securities currently on the market. Even mega cap stocks such as Meta (Facebook) and Tesla can see daily swings that pale in comparison to bitcoin at times. I remember Johnson and Johnson (JNJ) experiencing gut wrenching volatility during the March 2020 "Covid crash". JNJ has a AAA debt rating, an achievement not even the United States government can boast of. My point is that with an SEC head as well versed and educated on bitcoin as Mr. Gensler, this is the right time for the SEC to guide the public and educate the public so that they can make the choice of whether to invest and how much to invest for themselves, using a safe and efficient ETF vehicle. Please don't make us use a hacksaw to spread our butter, we would much prefer a butter knife.  

Sincerely, 

Manu Oberoi 
Real Estate Broker & Owner 
Bay State Brokerage