Subject: File No. SR-NYSEArca-2021-90

Apr. 22, 2022

 

Dear SEC,

The SEC is mandated to protect investors and by converting GBTC to an ETF it would be doing exactly that. As someone who purchased GBTC at a 10% premium as it had always sold at a premium. I didn't realize the price of the trust's shares could swing more wildly and with far more volatility than the underlying asset. At the time of this writing the GBTC discount to spot is over 20% and many investors myself included are now under water by that amount simply due to the current structure rather than fluctuations in spot Bitcoin. Converting to an ETF would be a far safer and a more reliable mechanism to get exposure to Bitcoin than the current trust structure which has been quite harmful to many investors, especially retail. The ETF would eliminate the premium / discount fluctuations which have been so harmful to investors. We highly recommend that GBTC be converted to a spot ETF that follows the exact price of Bitcoin which is what we want as retail investors.

Sincerely,

Mitchell J. Brodie, President
Commercial Real Estate Finance