May 22, 2022
Greetings: I write to ask that the Commission grant approval for a spot bitcoin ETF, for the following reasons: · The futures ETFs now offered are primarily oriented toward institutional investors, thus excluding myriad investors – many of them sophisticated allocators, Qualified Purchasers, and Accredited Investors – who would otherwise benefit from access to a spot BTC ETF. · Many regulatory agencies in other countries have recognized this, democratizing their markets accordingly – thus leaving the US at risk of losing the capital and talent that are necessary for future innovation. · Bitcoin has been available for over a dozen years and indeed in that time has been held mostly by retail investors. · The existing publicly traded trust structure(s) are suboptimal, featuring both higher fees and greater tracking error than an ETF would; this leaves investors in these trusts – who have no other publicly traded options at their disposal – at a distinct disadvantage, not least relative to investors in other countries like neighboring Canada. · The futures-based ETFs of course trade on the basis of the underlying spot BTC, so denying access to the publicly traded spot markets would seem counterintuitive. · Finally, it does not seem as though the spot markets are uniquely subject to manipulation relative to the futures markets; indeed, given the latent demand for spot BTC ETFs, there would appear to be sufficient liquidity and volume to make spot-market manipulation exceedingly difficult to effect – as the experience in other markets where they are now offered has in fact reflected. With this in mind I hope that you will see fit to move forward with this investor-friendly product, which promises to make an innovative technology more broadly available, while simultaneously making for more robust, transparent public markets. Respectfully submitted, A Concerned US Investor