Subject: File No. SR-NYSEArca-2021-90
From: Basel Hejjo Alrefai
Affiliation:

Apr. 22, 2022



Dear SEC,

I write to you as a GBTC shareholder, in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) — the world’s largest publicly-traded cryptocurrency fund — to an ETF. By not approving this conversion, you are not protecting me, the investor – the very person you were appointed to protect.
Last October, you approved futures-backed Bitcoin ETFs, but continue to reject applications for spot Bitcoin ETFs. Given that investors use both vehicles to gain exposure to the same underlying asset, Bitcoin—from which both vehicles derive their prices—we, as investors, should be able to choose if we’d like direct or futures-based exposure to that asset.

Furthermore, the discount to NAV in GBTC has been around 25%, on average, this year. This means that the price of GBTC is less than the price of Bitcoin, the asset itself. Given that GBTC has about $30bn in AUM, shareholders like me are experiencing a destruction of value of around $7.5 billion.
I’m writing from the state of Alabama,  with gratitude for the opportunity to express my view and with the hope that you will approve this conversion and protect the interest of investors.

For a fact,  I know of many local investors would like to gain long term position in their pensions in the form of spot BTC ETF.
Once again I like to urge the SEC in expediting the approval of of a spot bitcoin ETF to protect the retail investors long term portfolio especially with current world economy and so far bitcoin has proven  to be an asset ( not a security). An asset that continues to mature, gain adoption and grow its network effect.  Thank you

Sincerely,
Basel H Alrefai, MD