Subject: File No. SR-NYSEArca-2021-90 GBTC
From: Bryan Kelley
Affiliation:

Mar. 14, 2022

 


I strongly support the allowed conversion of GBTC to an etf backed by the actual underlying asset.  The existing futures based bitcoin ETF (BITO) 
is an inferior product that does little to protect investors and is plagued by fees and does not track the actual bitcoin price well.  If the concern 
for a spot ETF is market manipulation, then why is BITO allowed since that would be subject to the same issues?  An actual spot based bitcoin etf 
would be a much “safer” vehicle for many market participants than alternatives.  Investors are going to pursue and acquire bitcoin 
regardless of the SEC’s actions so why wouldn’t the SEC want a product that at least is under their umbrella and has regulatory oversight.  
Spot bitcoin etf’s are already available in many other countries and the United States should not fall behind in this critical technology category.  
I respectfully ask the SEC to please approve the GBTC conversion to a spot based bitcoin etf product.  
 
 
Bryan G. Kelley, P.E. 
 
Senior Traffic Engineer


Simmons & White, Inc.