Subject: File No. SR-NYSEArca-2021-90
From: Laurie Hesslein
Affiliation:

Apr. 22, 2022

 


Dear SEC, 

I write to you as a GBTC and ETHE shareholder, in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) and Grayscale Ethereum Trust (OTCQX: ETHE) — the world’s largest publicly-traded cryptocurrency funds — to an ETF. By not approving this conversion, you are not protecting me, the investor – the very person you were appointed to protect. 

Last October, you approved futures-backed Bitcoin ETFs, which may fit within the current oversight framework, but continue to reject applications for spot Bitcoin ETFs which would have lower investor expenses, less market risk and therefore, likely better performance. Given that investors use both vehicles to gain exposure to the same underlying asset, Bitcoin—from which both vehicles derive their prices—we, as investors, should be able to choose if we’d like direct or futures-based exposure to that asset. 

Furthermore, the discount to NAV in GBTC has been around 25%, on average, this year. This means that the price of GBTC is less than the price of Bitcoin, the asset itself. Given that GBTC has about $30bn in AUM, shareholders like me are experiencing a destruction of value of around $7.5 billion. 

I’m writing from New Jersey, with gratitude for the opportunity to express my view and with the hope that you will approve this conversion and protect the interest of investors. 

Sincerely, 
Laurie Hesslein