Apr. 26, 2022
Dear SEC, Thank you for taking the time to review my comments re: File No. SR-NYSEArca-2021-90. I write to you as a GBTC shareholder, in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) to an ETF. Your team has approved futures-backed Bitcoin ETFs, but have not yet accepted an application for a spot Bitcoin ETF. Australia has approved a spot ETF, along with Canada and many other countries we consider our peers from a financial and democratic perspective in the west. 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. The discount to NAV in GBTC has been more than 20% on average this year. Given that GBTC has about $30bn in AUM, shareholders like me are experiencing a destruction of value of around $7.5 billion. Approving GBTC's spot ETF application would rightsize this discount and bring the price of GBTC back to NAV— making investors whole. I’m writing from Idaho, 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 Layton