Subject: File No. SR-NYSEArca-2021-90
From: Kent Davis
Affiliation:

May. 06, 2022

 


Dear SEC Administrators, 

I write to you as a GBTC shareholder living in Florida. I hold shares in my IRA and they are down 51% since purchase. 


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


By approving this conversion, you will be protecting me, a retired 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. 

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. 



Just the conversion to ETF alone would recover 50% of my losses! 


Thank you for approving this conversion and protecting the interest of investors. 



With best regards, 


Robert Kent Davis