Subject: File No. SR-NYSEArca-2021-90
From: Steve Hubbs
Affiliation:

Jun. 02, 2022

Dear SEC: 



I have invested in the Grayscale Bitcoin Trust (GBTC) since March 2017. I have watched the premium with which this Trust trades at to the underlying asset Bitcoin go from 20% in March 2017 to 100% in Dec 2017 to now a 30% discount to Bitcoin. 


I also own Bitcoin and have it in cold storage in a Ledger Nano X. My bitcoin investment there was formed from March 2019 to July 2020 primarily and is currently up 227%. My GBTC shares were bought primarily from Feb 2018 to Feb 2020 so longer than the cold storage Bitcoin. Because of the drop from a premium to a 30% discount, my GBTC shares have only made 48% in unrealized profit. 


I am now wondering why I have invested in GBTC when Grayscale has repeatedly asked for a conversion of the trust to a Bitcoin spot ETF and you have not accepted their requests or anyone else's for that matter. I am only asking for fairness as an investor and that you accept Grayscale's request to convert the trust to a Bitcoin spot ETF. 


There is deep liquidity in the trust and that will continue as a Bitcoin ETF. The only manipulation I've seen in the trust is the loss of value from a premium to a 30% discount due to investor selling because it's much easier to buy Bitcoin on the crypto exchanges and just store it. 


The 2% fee that Grayscale charges me and other investors each year will be reduced with the conversion of the trust to a Bitcoin spot ETF. This would further protect the investors like me from high fees each year to manage this trust if it is converted to a Bitcoin spot ETF. 


The conversion to a spot ETF will unlock $8 billion in investor value which has been lost over the last few years due to the increasing discount. Bitcoin as a spot ETF will trade close to price of Bitcoin which it should to give investors fair value for investing in this trust for so many years. 


I urge you to approve the Grayscale Bitcoin Trust (GBTC) into the first Bitcoin spot ETF in the United States. 




Sincerely, 


Steve Hubbs 
GBTC long term investor