Subject: File No. SR-NYSEArca-2021-90
From: Troy M.
Affiliation:

May 31, 2022

Dear SEC,

I write to you as a longtime GBTC shareholder since 2016, in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) — the world’s largest publicly-traded cryptocurrency fund — to an ETF. By not approving this conversion, you are not protecting me, the investor – the very person you were appointed to protect.

Last October, you approved futures-backed Bitcoin ETFs, but continue to reject applications for spot Bitcoin ETFs. 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.

Furthermore, the discount to NAV in GBTC has been around 25%, on average, this year. When I originally purchased the shared, there was a premium of 60%+. With the discount today, the price of GBTC is less than the price of Bitcoin, the asset itself, and far less than the premium price from years ago. Given that GBTC has about $30bn in AUM, shareholders like me are experiencing a destruction of value of around $7.5 billion.

I’m writing from Arizona, 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,
Troy