February 13, 2022
Please approve the conversion of the GBTC closed end trust to an exchange traded fund. It is in the best interest of investors as it would lead to lower annual expense ratio, more liquidity (pre market and after hours trading) and ease of access for retail investors to gain exposure to spot Bitcoin within brokerage accounts at trusted custodians and asset managers. The current structure of the closed end fund has led to price of the fund trading at a premium and discount to net asset value which has created arbitrage opportunities for more sophisticated traders to take advantage of unsuspecting retail investors. Subsequent conversion to an ETF would lead to less arbitrage manipulation and a more accurate pricing correlated to that of the underlying asset value which is in the best interest of investors. This would also allow existing holders of GBTC to exchange baskets of shares for spot bitcoin, which currently is not possible. Many other developed countries have already established and provided access to bitcoin exchange traded funds. The United States of America should be leading the way on innovation within the financial markets, specifically digital assets and the cryptography sector. This is the future of finance and the conversion of GBTC to an exchange traded fund will be crucial to ensuring our country continues to lead the way in this future. After reviewing the proposed NYSE ARCA Filing, the structure of the fund is almost identical to existing commodity based exchange traded funds such as the SPDR Gold Trust (GLD) and Ishares Gold Trust (IAU). These exchange traded funds have allowed for retail and institutional investors to allocate capital within brokerage accounts in a low cost, efficient way for the better part of the last 20 years. Now is the time to convert the Grayscale Bitcoin Trust to an exchange traded fund as continued adoption accelerates. Thank you for your consideration.