Subject: “File No. SR-NYSEArca-2021-90”
From: Zachary Hollinshead, CPA, Director – Tax Services, Funaro & Co., P.C.
Affiliation:

May. 11, 2022

Dear U.S. Securities and Exchange Commission,

I am writing to you today to echo the sentiment of millions of others around the world, the desire and need of the conversion of Grayscales GBTC to a spot ETF in the United States.

According to your website, https://www.sec.gov/about/what-we-do, your stated mission is “…protecting investors, maintaining fair, orderly, and efficient markets, and facilitating capital formation.” By restricting the American public to a regulated spot ETF you are failing your mission. 

A spot ETF will protect investors from the ravishes of inflation and the whims of large capital pools. A spot ETF will promote fair orderly and efficient markets and facilitate capital formation better than a cash settled futures ETF. Large pools of capital have an ability to produce large balances of cash at little to no cost and push the underlying asset in an unfair, disorderly, and inefficient direction which thereby prohibits capital formation. And yet, you have not denied cash settled futures ETF. A spot ETF that settles in the underlying is critical in the maintenance of fair, orderly, and efficient markets, which thereby facilitate capital formation within the markets. 

Denial of the GBTC spot ETF would, as a matter of objective fact, be a gross miscarriage of your stated mission. I urge you to approve the GBTC spot ETF at once, in alignment with your stated mission.


Sincerely, 

Zachary Hollinshead, CPA, Director – Tax Services
Funaro & Co., P.C. 
http://www.funaro.com 

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