Subject: File No. SR-NYSEArca-2021-90
From: C. Pisano
Affiliation:

May. 07, 2022

Dear SEC, 

 

I am a GBTC shareholder in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) to an ETF. 

 

By not approving this conversion, you are not protecting me, the investor – the very person you were appointed to protect. 

In October 2021, the SEC approved futures-backed Bitcoin ETFs yet continues to reject applications for spot Bitcoin ETFs. Investors use both vehicles to gain exposure to Bitcoin and should be able to choose if we’d like direct or futures-based exposure to Bitcoin. 

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, existing shareholders like me are experiencing a destruction of value of around $7.5 billion. 

GBTC is the world’s largest publicly-traded cryptocurrency fund, with hundreds of millions in daily trading volume. It holds approximately 3.4% of all Bitcoins outstanding, and is held by more than 850,000 investors, like me. 

I’m writing from California and am grateful for the opportunity to express my view with the hope and expectation that you will approve this conversion and protect the interest of investors. 

 

 C. Pisano