Subject: File No. SR-NYSEArca-2021-90
From: Son Vann
Affiliation:

May. 09, 2022

Dear SEC, 

I write to you as a GBTC shareholder, in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) to an ETF. I have been a holder since mid-2020 when I viewed the actions of the US Treasury and Federal Reserve Bank as adding risk to the US dollar. As a hedge, I diversified to add Bitcoin. At the time, investing directly into cryptocurrencies was difficult for storage and electronic security reasons. It is much easier now to own the cryptocurrency directly, but I prefer an ETF for liquidity and minimum size reasons. I consider myself knowledgeable of the risk of cryptocurrencies and specifically Bitcoin. By not approving this conversion, you are not protecting me, only making it more costly from a management perspective. 

Last October, you approved futures-backed Bitcoin ETFs, but continue to reject applications for spot Bitcoin ETFs. I see the risk in a futures ETF as significantly greater than one that tracks the underlying asset. 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. 

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, 
Son Vann 






Son