Subject: File No. SR-NYSEArca-2021-90
From: Jeffrey Bush
Affiliation:

May. 06, 2022

Dear SEC 

I am writing as a longtime GBTC shareholder who is 100% in FAVOR of and SUPPORT the conversion of GBTC to a spot ETF. It is actually embarrassing that the United States of America is falling behind in this advanced technology by allowing other countries to bring these investment vehicles (BTC spot ETFs) to market before us. Since when is CANADA better than US?? 

Secondly, many investors are not able to invest in BTC directly via crypto exchanges, so opening up a spot ETF to them that they can buy within their current financial institutions will allow them access to this investment option. Currently you are denying them that option, and by doing so you are directly causing them to fall behind as this tech moves forward and increases in value. 

If a BTC futures ETF can be approved, why not a spot ETF? Do you think people understand the workings of a futures derivative product better than they a spot product? If anything, you are encouraging investors that know nothing about "futures" to buy something they shouldn't (a futures-based ETF) because it is the only thing currently available and they don't understand that they are not actually buying direct exposure to BTC. 

A spot ETF would be MUCH simpler and more straightforward for everyday investors. And it will be regulated by you, causing the "manipulation" you seem to concerned about to actually lessen. And at least investors would be gaining direct exposure to bitcoin (which is what they want) rather than a futures derivative. 

Please stop "protecting" us when anyone in the US can go to Vegas and drop their life savings on a roulette wheel or craps table. 

GBTC already holds between 3-4% of all BTC outstanding. You might as well approve its conversion to an ETF, because anyone else you approve would need to buy so much BTC that would indeed influence and "manipulate" the market. GBTC already has a massive store of the asset. They are ready. 

Look, investors are looking for a straightforward access to bitcoin and other crypto currencies and upgrading GBTC to an ETF would absolutely accomplish this objective. PLEASE listen to the people writing to you and APPROVE this conversion. It is about time. 

Sincerely, 



Jeffrey Bush