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.

A Bitcoin spot ETF is by far the best alternative for investors looking to get exposure to the asset. The issues with future based
ETFs and the rolling of contracts are well known in ETFs like USO and VXX. Having a Bitcoin ETF that is not backed by futures is 
the best way to provide access while minimizing risk and cost to investors.

For thousands of investors, the Grayscale Trust already works as an ETF but it should not be limited on conversions between Bitcoin 
and shares. The discount to NAV has been significantly impacting investors. Allowing the trust to convert would also bring a new level 
of transparency and regulation.

I’m confident the SEC will finally approve a Bitcoin based ETF. This is way past due. Bitcoin is here to stay and Investors will 
continue to allocate to the asset class. Either directly or through an ETF. As a long time investor I urge your team to carefully 
analyze the impact these delays have had on Investors and why the time is more than ripe for an approval.

Sincerely,
Raph Zagury