Subject: File No. SR-NYSEArca-2021-90

Feb. 22, 2022

 

Dear SEC,  

I’m writing to support the conversion of Grayscale Bitcoin Trust (Symbol: GBTC), currently the world’s largest Bitcoin fund, to the first Spot Bitcoin ETF in the United States.  

Investor protection is needed from the Grayscale GBTC premiums/discounts. Unfortunately, brokerages do not offer me a way to directly purchase bitcoin so the GBTC closed end fund is the closest way for me to gain exposure to the asset class. However, due to it being a closed end fund, the premium/discount to NAV fluctuates to extreme degrees. I could purchase GBTC while bitcoin is up but the GBTC discount is going negative which leaves me exposed because GBTC is not a spot based ETF. If it were a spot based ETF this would allow redemptions and the premium/discount to be non existent. To confirm this, I track the Canadian ETFs daily and they never exceed a 1% discount/premium to NAV where GBTC has seen a +40% premium & -30% discount to NAV. 

Please help protect investors and convert the GBTC product into a Spot ETF. 


Sincerely,  
Michael Samilow