Subject: File No. SR-NYSEArca-2021-90
From: Gary Spiess
Affiliation:

May. 07, 2022

 

Dear SEC, 

I speak in favor of converting Grayscale Bitcoin Trust from a CEF into an ETF that can be listed on NYSE Arca. I hold less than 5% of my retirement portfolio in GBTC. The fund provides a way for me to invest in bitcoin as part of my financial plan. 

The cost and risks to the investor are substantially lower if bitcoin could be added to a portfolio the same way as gold. It avoids the CEF potential for large price premium/discount over NAV. It avoids derivative risks of ETFs based on bitcoin futures. It allows an investment in the asset without the risks associated with directly buying, selling and storing bitcoin. 

Canada has allowed physically backed bitcoin ETFs. I am certain that the US SEC can regulate bitcoin ETFs so the risks are similar to directly owning bitcoin. 

Gary Spiess