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

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 hold GBTC in a taxable account and the maintenance selling fees causes a serious capital gains calculation on my income tax each year. I believe the conversion to an ETF solve that problem. 

I’m writing from North Carolina 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. 

Sincerely, 
Gary E Jones