May 13, 2022
May 13, 2022 Ms Countryman, I am in favor of approving the application to convert shares of Grayscale Bitcoin Trust (BTC) under NYSR ARCA Rule 8.201-E. As an individual investor I have been following the evolution of digital assets and markets for several years. I made the decision to invest in GBTC as it was in my opinion the most efficient and safest way for me to gain investment exposure to the underlying asset, Bitcoin. The fact that GBTC is not allowed to trade as a spot ETF has resulted in GBTC actually becoming one of the least efficient ways to gain investment exposure to Bitcoin. The SEC has approved the futures based Bitcoin ETFs but in my opinion these are not appropriate investment products for a long-term investment. This is driven by the three D's: 1) Diluted Exposre 2) Divergence 3) Decay The mission of the SEC is to protect investors maintain fair, orderly, and efficient markets and facilitate capital formation. In my opinion the current disount of the shares of GBTC does not represent a fair, orderly, or efficient market. I also believe that the combination of liquid markets for Bitcoin and the features within the ETF structure mitigate potential price manipulation a key factor expressed by the Commission in past decisions to disapprove filings similar to the Notice. Lastly, oher regulatory entities outside of the United States have approved spot based ETF products. Why is the United States lagging on this front? Why am I put at a disadvantage as an American investor? Thank you for the opportunity to comment on this rule change. I look forward to a favorable ruling and that this rule change is approved in short order. regards, Keith Brandt