Subject: File No. SR-NYSEArca-2021-90
From: Jonathan Booker
Affiliation:

May. 10, 2022

Dear SEC, my name is Jonathan and I am currently completing a year of service with AmeriCorps in the state of Alabama. I committed to this year of service because I wanted first hand experience with the root causes and common treatments for poverty in my state. While doing taxes for low-income individuals, I would often come across people who would hopefully ask my opinion on Bitcoin and other crypto currencies. They asked me because they wanted me to confirm their suspicions that Bitcoin could represent a new era in the financial sector—a sector which has for many years grown its share of GDP without providing common goods to Americans which can be enjoyed by all, rich and poor. In short, they are wondering if Bitcoin is the beginning of a system that is more fair to them. 


The question before you, however, is whether a spot BTC product is safe for retail investors. Indeed fortunes are made and lost among reckless investors with little experience, but this risk exists with or without Bitcoin, and is exacerbated as much by retail access to margin as by retail’s access to volition assets such at Bitcoin. The Bitcoin spot ETF would be in excellent hands with Grayscale, and it would give people like those I spoke to greater access to a financial product which they yearn to see succeed. The SEC should not deny people the opportunity to invest in a product which they care about personally and which presents no more of a risk than other products that are available to them currently. 


Therefore, I am in favor of approving the Form 19b-4 that NYSE Arca filed with you to convert Grayscale Bitcoin Trust (OTCQX: GBTC) – the world’s largest publicly traded crypto asset fund, with approximately $30 billion in AUM, hundreds of millions in daily trading volume, more than 850,000 investors, holding approximately 3.4% of all Bitcoins outstanding – 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 assets, Bitcoin. With approximately $30 billion in AUM, that results in approximately $7.5 billion of trapped value from existing U.S. investors. 


Sincerely, 
Jonathan Booker