Subject: rule-comments@sec.gov
From: George Vascellaro
Affiliation:

May. 02, 2022

To whom it may concern:

From: George Adam Vascellaro

        I am in full support of GBTC’s effort to become an ETF as soon as reasonably possible as currently it is a OTC Trust with much higher expenses than traditional ETF’s.   I have invested for 20 years now and am an accredited investor.

Even thought I’m relatively late to crypto 2021 and down around 40%. currently it doesn’t bother me.   I think the future is bright and the United States should always be on the highest risk / reward edge of the future.

As far as risk go I don’t feel crypto is any more than stocks, look at the stock market, especially tech and high growth names which are faring far worse than crypto to the feds actions.  I have been hurt / scammed by stocks and politics far more often than I have in crypto thus far.  I have owned hundreds of stocks over the years and probably had 30 or 30 go bankrupt.  Many of those heavily regulated.   I had $30,000 invested in “value" coal companies for steady income and lost it all when a president mentioned they were going to bankrupt the coal industry and they did it with regulation.  I have had companies fake accounting and fool regulators for years. I have seen reverse splits dilution, abusive fees / hidden fees, undervalued sales and most of this retail investor value destruction legally done in an environment to “protect” the consumer.

The bottom line is a recurrent theme of successful financial success is getting in early.  Something often accredited investors can do but in an inequitable fashion not something unaccredited investors can do.  Rich people have access to these funds overseas where middle to low class do not.   They have to buy through crypto exchanges where the real exponential scamming risks are.   Spend a few weeks in the NFT world and you’ll quickly see what I mean.

Why not allow people to gain access to crypto ETF’s in the top 10 names by market cap in a product with reasonable fees that we don’t have to self custody and can name a beneficiary on (Big issue you can’t do on coinbase, FTX, Voyager, ETC.), get help recovering a password or gaining access?

Personally I diversified 10% of my assets into Crypto.   75% of that via OTC trusts I have access through in an investment account that can be both in mine and my spouses names (Something crypto exchanges can’t) and again we are each other’s beneficiaries.  Even thought over the long rung the trust fee’s are going to eat 20 to 40% of our profits (without a low cost ETF's or Index funds competing for our business) .  But never the less that is where we have the most security comfort and they also have to track first in / first out / long term gains, etc.  It seems like the SEC would want the added custody, security, traceability, beneficiary designatable, access through already regulated / well established, tax record compliant US companies.

I worry about crypto exchanges / wallet getting hacked ransomed or some scam than I do the trust’s I hold in TD ameritrade. I also worry far more of my family and friends getting left behind long term since they have little access to safe / cost effective crypto far more than I concern myself with anyone getting short term wealth from it.

Again if there was a reasonable cost way for all in my family to invest in a SEC approved BTC ETF I would only think it would be prudent and what is truly best for all.   Currently my understanding is Morgan Stanley is the largest holder of GBTC.  If this is true it seams like they have been given the chance and more than adequate time to front run the general public and sell it to them at a handsome profit once the ETF is approved.   I own Morgan Stanley and all the other big banks / investment banks for that reason.  You can beat them so join them.

It would have been nice to know that fidelity has been mining BTC since 2014 and now they are creating a retirement product where we can have access to it.  Why wouldn’t investors diversify 3, 5 or 10% into it the same way we did REITS (Which were risky) and Inflation protected bonds (Nice investment to have now)


Thanks for the consideration.