Subject: File No. SR-NYSEArca-2021-90
From: Anton Delport
Affiliation:

May. 06, 2022

 


Dear SEC, 

A significant portion of our retirement savings is tied up in an asset you have been reluctant to approve as a spot ETF. This money is locked into a fund that many of us hoped would be an ETF by now. Because of the lack of approval by the SEC, and the approval of spot ETFs for bitcoin in many other jurisdictions like Canada, our investment in the GBTC fund is now trading at a significant discount compared to the premium we purchased it. This has resulted in significant losses, since spot ETFs now exist in other jurisdictions. Please consider the large number of investors depending on your decision, and also please consider that nothing adverse has happened to investors living in jurisdictions outside the USA where spot ETFs for bitcoin have been approved. We write to you as GBTC shareholders, in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) the world's largest publicly-traded cryptocurrency 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 would 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. We are writing with gratitude for the opportunity to express our views and with the hope that you will approve this conversion and protect the interest of investors. Sincerely, Anton and Elva Delport