Subject: File No. SR-NYSEArca-2021-90
From: Alec Montgomery
Affiliation:

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.
The time to protect retail investors from the risks associated with this trust structure was when the larger private placement investors were allowed to take advantage of the scarcity value of the bitcoin trust as one of the few ways for retail investors to gain access to bitcoin exposure by selling onto retail investors at large premiums - which have now turned into large discounts.
Now the delay in allowing Grayscale to convert the trust to a spot bitcoin ETF is simply prolonging the punishment that retail investors have suffered by investing in the only available structure “approved” by the SEC and paying fees that are inordinately high to the manager.
Stop imagining risks that might happen and start addressing the issues that are hurting investors.

Sincerely,
Robert A. Montgomery