Subject: File No. SR-NYSEArca-2021-90
From: Sean O'Farrell
Affiliation:

May. 08, 2022

Dear SEC: 


Please consider what is overdue and right for the markets and the people involved in those markets, converting the Grayscale Bitcoin Trust (Symbol: GBTC), currently the world’s largest Bitcoin fund, to the first Spot Bitcoin ETF in the United States. 

Not approving this is a disservice to all and weakens your credibility to those in the US and throughout the world. The framework for this is already in place and crypto and more specific Bitcoin is apart of the daily life of everyone in this world. 

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

I’m writing from Colorado, 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.
 

 Thanks, Sean O'Farrell