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

Apr. 23, 2022



***[PLEASE CUSTOMIZE WITH YOUR VIEWS ON THE CONVERSION, INCLUDING WHICH STATE YOU RESIDE IN – THANK YOU FOR YOUR SUPPORT]***

Dear SEC,

I have been a shareholder go GBTC and ETHE for almost a year. I am writing to you to ask to expedite the approval of the conversion of both funds into 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, but continue to reject applications for spot Bitcoin ETFs. 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.
In my opinion, a spot ETF will be a much better vehicle for investors. Unlike a futures-based one, it will not be affected by contango / backwardation fluctuations. Canada has spot ETFS for a few years by now.

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,
Vadim Khidekel