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

May. 06, 2022

Dear SEC, 

I write to you as a GBTC shareholder, in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) fund to 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. I believe that a spot Bitcoin ETF is necessary to create a level playing field for investors. Allowing futures and options trading for Bitcoin only enables investors interested in price speculation. The long term investor is not getting a seat at the table without a spot ETF. 

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 $30 billion in AUM, shareholders like me are experiencing a destruction of value of around $7.5 billion. 



Grayscale has proven to be a secure custodian for Bitcoin over the years and should be given the opportunity to address their investor needs. 

I am writing from Florida, 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, 
Robert Chambers