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

Mar. 09, 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 SEC needs to work with Grayscale and figure out a way to convert GBTC to a spot bitcoin ETF. I have given more than 50 television, newspaper, radio, and magazine interviews since 2017 regarding bitcoin. I can tell you there are tens of thousands of people ... many who are at or near retirement age ... who have lost a big chunk of their retirement savings because they bought GBTC when it was trading at a Premium to Net Asset Value in 2020. Many of these people knew that the premium would eventually evaporate ... but they had no idea that the Premium of ~15% would or could turn into a ~25% discount. Anyone who bought ~15 equivalent bitcoin in GBTC ~18 months ago is now sitting on the equivalent of ~9 bitcoin ... 

... so they already lost 40% of their life savings in ~18 months. 

I have been on Wall Street for 25 years. I was one of the first analysts on Wall Street to put my stamp of approval on bitcoin ... in July 2017 < www.bloomberg.com/news/articles/2017-07-05/bitcoin-to-50-000-is-latest-call-from-prolific-stock-picker > and according to TipRanks I was in the top 1% for my performance 2008-2020 > that ranking covered more than 500 time-stamped stock recommendations I put out for my < www.standpointresearch.com > subscribers. I understand your hesitation. That said, your approval is overdue. You need to work with Grayscale and fast-track the conversion of GBTC to a spot price bitcoin ETF instead of rejecting it based on reasoning that is outdated. By converting GBTC to an ETF ... it would allow this name to more efficiently track the price of bitcoin and eliminate (reverse) the existing discount. It is also possible that Grayscale would then be able to reduce their management fees for GBTC as well.  




Sincerely, 

Ronnie Moas