Subject: File No. SR-NYSEArca-2021-90
From: Petr Pacas
Affiliation:

Feb. 25, 2022

 


Hello SEC and Gary Gensler,  


Please consider this email as a request to convert GBTC into a spot based Bitcoin ETF.  


ETF conversion from the GBTC trust is the right move to make, especially if you care about protecting investors.  


I am sure you're familiar with the discrepancy, currently a 25% discount, compared to the spot price of BTC. When you look at the history, the premium and/or discount amplifies volatility of GBTC during downturns and upturns. This means that GBTC is currently more dangerous to investors than the actual BTC market. More importantly, it can be avoided. 


If you can track the bitcoin price precisely, it's better than attempting to track the bitcoin price through a secondary market, which is what's happening currently with GBTC. First-party data is almost always better than third-party data. You are the decision maker who can lower volatility on this OTC product. I urge you to take action and step in! 


As a result of this conversion, you'll improve investor confidence, which would also likely add a more solid bottom to the BTC price.  


Please 1) prevent the leakage, 2) lower the Grayscale fees, 3) mute GBTC's volatility, and 4) provide more liquidity to the BTC markets with this single action. Do it sooner rather than later - because you can and it's the right thing to do.  


Thank you,  


Pete Pacas