Subject: Comments regarding File No. SR-NYSEArca-2021-90
From: John Svoboda
Affiliation:

Apr. 22, 2022

 


Dear SEC,
 
I write to you as a GBTC shareholder, in support of the conversion of Grayscale Bitcoin Trust (GBTC) to an ETF. By failing to approve this conversion, you are not protecting me, the investor – the very person you were appointed to protect. 
 
In October of 2021, 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. 
 
Also, the average discount to NAV in GBTC this year has been around 25%. This means that the price of GBTC is less than the price of Bitcoin, the asset itself. 
 
Given that GBTC has about $30 billion in AUM, shareholders like me are experiencing a destruction of value of around $7.5 billion.
 
I’m writing from Michigan, with gratitude for the opportunity to express my view and with the hope that you will approve this conversion and protect the interests of investors. 
 
Sincerely,
John Svoboda