Subject: File No. SR-NYSEArca-2021-90
From: Sunil Nariani
Affiliation:

May. 06, 2022

 


Dear SEC 
I write to you as a GBTC shareholder , in support of the conversion of Grayscale Bitcoin Trust (OTCQX%3A 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%E2%80%94we , as investors , should be able to choose if we%E2%80%99d 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 about30bn in AUM , shareholders like me are experiencing a destruction of value of around 7.5 billion. 
I'm writing from Texas , 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. 


Sincerely 

Sunil Nariani