Subject: File No. SR-NYSEArca-2021-90

Mar. 03, 2022



Dear SEC,

I am 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 world is growing and will continue to grow more demand for currencies which diversify down exposure to geopolitical risk, and give exposure to burgeoning industries reliant on blockchain technology like invoicing, lending, evolving crowd-investing (for example, crowd-investing in a large-scale book publish), decentralized social media, decentralized media storage and streaming, decentralized computing services, maximized-efficiency value storage and transfer to improve things like remittance payments and multi-sends, escrow services, and all derivatives of non-fungible token (NFT) technology (royalties, club memberships, real estate ownership, event ticketing, and customer loyalty reward programs, for example). Investment vehicles like the GBTC have grown to support the initial growth phase of this industry, but have grown price-inefficient over time, are still difficult to access for most who want exposure to this new industry, and effectively results in most demand pushing custodial services through fewer outlets.

There was a time when only speculators should have exposure to the technology while it’s in its infancy, at which point a barrier to entry makes sense, to limit societal impact of an asset class which could be divergent (fragile), but enough access is still possible to allow it to grow.

That time has passed. As recent world events have shown, entire populations want access to vehicles of value which can act as hedge or non-correlation to geopolitical risk. They want an alternative to gold. The unbanked world can now grow banked. The use cases of the new industry have proven that they’re here to stay, and cryptocurrencies like Bitcoin have by now stood the test of time. And inefficient walled-garden vehicles like GBTC can now be allowed to be price- and time-efficient, and opened to the general industry for ease of access and to start spreading custody channels. The demand, the stability, and the societal need are now all present for the growth of cryptocurrency ETF’s. Let’s not let the USA fall behind in opening up access to it for our citizens.

Best,
William Keller