Subject: File No. SR-NYSEArca-2021-90
From: Eric Michaels
Affiliation:

May. 10, 2022

Dear SEC,

I’m writing to support the conversion of Grayscale Bitcoin Trust (Symbol: GBTC), currently the world’s largest Bitcoin fund, to the first Spot Bitcoin ETF in the United States.

As a Canadian I invest in American equities because of the belief in American rule of law and the unbelievable entrepreneurial spirit and strong corporate culture. I have been able to buy Canadian spot BTC ETFs and have been very pleased with the experience. I believe in self-custody but also think it’s a good idea for exposure through tax advantaged accounts through my bank.

I have a lot of respect for Gary Gensler, as I believe he understands Bitcoin at a deeper level than I do. But I would like to add my point of view to the conversation. Of course the US market is far larger than the Canadian one, but as we’ve seen the spot ETFs here haven’t had problems. Respectfully, it seems like there are two reasons the BTC ETFs have not been approved in the United States. 1) The administration has said not to approve them because it will provide them more time to define their strategy if Bitcoin becomes too large. I hope that is not the case as BTC is an asset, not a currency that will challenge the US dollar. 2) Holding back a BTC ETF puts pressure on exchanges to register with the SEC. The problem with this is that it looks ‘wrong’ to the public. Of course legislation from Congress can direct who has authority over what region within the cryptocurrency sphere, rather than the enforcement action.

I hope the distinction between Bitcoin and other cryptocurrencies to be made. The proof-of-work mechanism where no one has more power over the protocol than anyone else is vital to Bitcoin. The ability to run a node and achieve true decentralization is likewise the same.

I look forward to the day that the public can invest in Bitcoin in a way that is comfortable for them, because I believe that: it gives property rights to those living in authoritarian regimes; monetizes renewable energy; reduces fees for merchants through the Lightening Network, etc.

Thank you for reading,
Sincerely,
Eric Michaels