Subject: File No. SR-NYSEArca-2021-90
From: Robert Wright Wilson Jr, CPA
Affiliation:

May. 09, 2022

Dear SEC,

I am writing to you as a shareholder of the Grayscale Bitcoin Trust (OTCQX: GBTC). I am in support of the conversion of GBTC to a spot Bitcoin ETF. I am not up to date on the reasons for why you are not approving this conversion, but certainly do not feel you are protecting me as the investor by the lack of approval. 

Last year, the SEC approved futures-backed Bitcoin ETFs, but have continued to reject or defer approval of applications for spot Bitcoin ETFs. Given that both vehicles gain exposure and derive their prices from the same underlying asset - Bitcoin, I do not understand the rejection of approval of the spot ETF. Though I have some futures based exposure, I prefer more direct exposure to the asset.

Finally, the discount to NAV in GBTC has been about 25% 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 reduction of value of around $7.5 billion.

I’m writing from Texas, and appreciate the opportunity to express my view and trust that you will approve the conversion of GBTC to a spot ETF and protect the interest of investors.

Sincerely,
Robert Wright Wilson Jr, CPA (retired)






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