Subject: File No. SR-NYSEArca-2021-90
From: Kenneth Benson
Affiliation:

May. 10, 2022

Dear SEC,

My name is Kenneth Benson from Klamath Falls Oregon and I am in favor of approving the Form 19b-4 that NYSE Arca filed with you to convert Grayscale Bitcoin Trust (OTCQX: GBTC) into a Bitcoin Spot ETF.

This year, GBTC has traded at an approximately 25% discount to its NAV, which means the price of GBTC is less than the price of its underlying asset, Bitcoin. With approximately $30 billion in AUM, that results in approximately $7.5 billion of trapped value from existing U.S. investors.

I believe it is important to level the playing field. To date, the SEC has only permitted Bitcoin Futures ETFs, while rejecting “physically-backed” or Spot Bitcoin ETFs. The choice should be mine. I should not be forced into a Futures-based product simply because it’s the only one that exists.

It would open the opportunity to many touplist from OTCQX to the New York Stock Exchange. The ETF would more efficiently track the price of Bitcoin, effectively eliminating premiums and discounts and Grayscale would reduce management fees for GBTC. These are all good for consumers (me).

Sincerely,

Kenneth Benson