Subject: File No. SR-NYSEArca-2021-90
From: Peter Day
Affiliation:

Feb. 27, 2022



I am writing this for you to please allow Grayscale to convert it’s Trust products into spot ETFS.

for GBTC, ETHE, ETCG and their trusts.

It’s incredibly destructive for share prices, the way that the trusts are currently set up. Because there can be negative premiums and the trusts (currently) don’t properly track the underlying asset prices.

For example, GBTC has a 20% negative premium and ETCG (the Ethereum Classic Trust) has a 58% negative premium.

Once  these are converted to spot ETFS, the premium will tighten up to 0% and this will be a far safer investment structure for investors, like myself, who are retail investors.

This is a needed move, not only for GBTC but the whole line up of Grayscale Trusts on the stock exchange.