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

May. 06, 2022



Dear SEC,

I write to you as a GBTC shareholder, in support of the conversion of GBTC. By not approving this conversion, you are failing to protect me, the investor – the very person you were appointed to protect. But… perhaps m that is not truly your goal…

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.

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 Connecticut with real hope you do the right thing and approve this conversion.

- Anthony Hammond