February 22, 2022
Secretary, Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-1090
RE: File No. SR NYSE Arca -2021-90
I strongly support Grayscale's proposal to have a spot Bitcoin ETF and believe it will be a benefit to all parties. BITO, a future's based product doesn't do a whole lot to mitigate any fraud or manipulation with the core asset it's 'tracking'. In fact it's likely worse as there will be a premium (positive/negative) based on the fluctuation of BTC. The current structure of the Grayscale Bitcoin Trust shares, GBTC, seems to be vulnerable also at this time to manipulation between the NAV of the Trust's BTC holdings and the shares price. There have been big premiums and discounts of the share price. The stated goal of the Trust is to have the GBTC shares trade at NAV and I believe your approval of the plan will greatly assist in meeting the objective of shares trading at NAV. The NAV is what investors expect Greyscale’s GBTC to trade at. So I really hope you will approve Grayscale's plan. Additionally, approving GBTC proposal will allow for a large inflow of dollars (billions) into the BTC market cap. This will help reduce volatility since at that point Grayscale will be one of the largest custodians of BTC. It will help to decrease any kind of manipulation. Grayscale's GBTC is already very large and they are asking for a simple conversion from a trust to spot ETF. They have a proven track record of financial integrity. They should lead the pack. Also, Grayscale has been very transparent which is a very good thing, thus the SEC note that, millions of Americans are looking for a way to purchase crypto from a trust worthy source. I believe Grayscale’s GBTC is that source, please approve them as a spot ETF.
Kindly,
Roger A. Rector
Seaside Ca.