Subject: File No. SR-NYSEArca-2021-90
From: Jason Cooper
Affiliation:

Apr. 07, 2022

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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. 

I am a CFA Charterholder and work at RW Baird where my team oversees model portfolios and acts as consultants to FAs. There is immense demand from their clients for a Spot Bitcoin ETF. 


I also serve as the Bitcoin analyst (pro incorporating into a client's portfolio at a small size to enhance Sharpe). Despite my favorable stance I explicitly recommended avoiding Btc Future ETFs due to the immense roll costs, which totally negate the benefits to holding an aspirational SOV in one's account as a longterm low corr investment. 


I truly don't understand your reluctance to allow conversion from a high fee close end grantor trust to an ETF, which would significantly benefit current shareholders and allow btc to be more easily held by the broader investing public. 

Sincerely, 


Jason A. Cooper, CFA