Subject: File No. SR-NYSEArca-2021-90
From: Divine Domicile
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. 

There are other countries that already have a spot Bitcoin ETF and the United states should be at the forefront of this movement towards digital assets. Instead, I fear that we are falling behind the rest of the world and this does not have to occur. I beseech the SEC to act with urgency regarding a spot Bitcoin ETF so we can be the guiding force behind the digital asset revolution.

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 New York 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,
*** Ray Anson Jones ***