Subject: File No. SR-NYSEArca-2021-90
From: Phil & Robyn Cooper
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) to an ETF.  By not approving this conversion, the SEC is withholding the full capability of my investment to deliver return.

Last October, futures-backed Bitcoin ETFs were approved, but your agency continues to reject applications for spot Bitcoin ETFs.  Given that investors use both vehicles to gain exposure to the same underlying asset, why not give investors the opportunity to choose between direct and futures-based exposure.

Moreover, 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.  This amounts to a significant diminution in the investment’s value.

As an investor, I did my due diligence before investing in GBTC and fully understand the risks involved.  I invested in it with about 1/2% of my portfolio since I am retired and do not have a long time horizon before me.  My investment could become worthless.  However, I like the speculative nature of Bitcoin and wish to have exposure to this potential.  There is no need for you to worry about protecting me if that is your hesitation in allowing the conversion.

I’m writing from Wisconsin, and appreciate the opportunity to express my view.  I hope that you will approve this conversion.

Respectfully submitted,

Phillip S. Cooper
GBTC Investor