Subject: “File No. SR-NYSEArca-2021-90”
From: Mike Cammarata
Affiliation:

Mar. 31, 2022

 


Hello,

I would like the SEC to approve the conversion of GBTC (Grayscale Bitcoin Trust) into a proper ETF (Exchange Traded Fund).

I believe that an ETF that is 100% backed by spot Bitcoin is far superior to a Futures based ETF that is solely backed by futures contracts.

Previously the SEC has been hesitant to approve a spot Bitcoin ETF citing concerns relative to pricing transparency whereby the price of spot Bitcoin is determined on unregulated exchanges today such as Coinbase, Kraken, Gemini, etc.

While the SEC cites the risk of spot Bitcoin price manipulation, the size of the Bitcoin market (around $1 Trillion USD) has now reached a level where price manipulation concerns are minor as any attempt at manipulation will simply be arbitraged away by the deep pool of robust market participants.

A spot Bitcoin ETF would further enhance the liquidity of the market leading to even greater levels of price discovery.

Whereas the existing Grayscale Bitcoin Trust is disadvantaged by the rules of the Trust, is unable to create / destroy shares like an ETF would, and has resulted in massive price discrepancies sometimes trading at a wild premium and other times trading at a steep discount.

Approving the conversion of the Grayscale Bitcoin Trust into an ETF would further grow the size and liquidity of the spot market for Bitcoin.

The GLD Gold spot ETF has shown that this type of product can be both successful in the marketplace and safe for investors.

Thanks!


Mike Cammarata • Vice President - Sr. Engineer