Subject: File No. SR-NYSEArca-2021-90
From: Michael Dunn
Affiliation:

Apr. 07, 2022

CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. 

Dear Officer, 

I am 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. 

I reside in Texas, but work in NYC. To date, the SEC has only permitted Bitcoin Futures ETFs, while rejecting “physically-backed” or Spot Bitcoin ETFs. Investors deserve a Spot Bitcoin ETF. GBTC is already the world’s largest Bitcoin fund and regularly reports to the SEC on a voluntary basis as an SEC-reporting company. If GBTC is approved to convert to an ETF by the SEC, a few key things would change: 
- GBTC would uplist from OTCQX to the New York Stock Exchange  
- The GBTC ETF would more efficiently track the price of Bitcoin, effectively eliminating premiums and discounts 
- Grayscale would reduce management fees for GBTC 



All of these offer significant material benefits, currently denied, to US investors. I would accordingly appreciate your thoughtful consideration and quick approval of a GBTC Spot ETF.  


Sincerely, 
Michael Dunn 



















Michael Dunn Law PLLC | 450 Lexington Ave., 4F | New York, NY 10017 
direct 646-546-5437 | fax 888-788-8452 | email mdunn@michaeldunnlaw.com