Subject: File No. SR-NYSEArca-2021-90
From: Eric Zimmerman
Affiliation: IT Professional

February 15, 2022

Please approve the conversion of the Grayscale Bitcoin Trust (GBTC) to an ETF.

I am a small retail investor in the US with a good portion of my savings in retirement accounts. I am also a proponent of bitcoin and would like to invest in the growth of this technology.

I was excited to discover that GBTC was available in my 401k and so I purchased shares as a vehicle to invest in bitcoin. Unfortunately, this investment has performed poorly, nowhere near matching the performance of the underlying Bitcoin. As I've discovered, this lag in performance is due to the closed-end nature of the trust and the inability to redeem the underlying assets. I've seen my investments fall from a 20% premium to a nearly 30% discount (a 50% swing to the negative)

Conversion of GBTC to an ETF would provide small investors in the US such as myself with a safe and reliable way to invest in Bitcoin in our 401ks. Conversion would also protect those investors who purchased GBTC at higher premiums and have seen the fund drop to a large discount.

Many of us are trapped in the fund due to the premium erosion and are in the difficult position of having to pay the high 2% management fee of the fund.

Allowing conversion of GBTC to an ETF will provide a effective route to recovering losses for the small investor, and provides US investors with a safe and efficient way to invest in bitcoin. Rejection of the conversion will continue to punish the small investor.

Please protect small retail investors by allowing conversion of GBTC to an ETF.