Subject: File No. SR-NYSEArca-2021-90
From: Dave Lamb
Affiliation:

Apr. 22, 2022


Dear SEC,

I write to you as a GBTC shareholder, in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) — the world’s largest publicly-traded cryptocurrency fund — to an ETF.
I have owned this stock for over two years now.  One of the challenges of this closed fund is that while following Bitcoin, it still has its own market demand, so there’s not that strong of a correlation to BTC, say as a gold backed ETF is to the price of gold.

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, but continue to reject applications for spot Bitcoin ETFs. A Futures based ETF is not that good for investors since the volatility of BTC is so high, the costs associated with Futures transactions would be extremely high.  While good for the investment firms, it would be a very costly the investor.  Owning BTC directly would make more sense.

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 Arizona 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,
David Lamb