Subject: File No. SR-NYSEArca-2021-90
From: Gary Bechtold
Affiliation:

Apr. 22, 2022


PLEASE UPDATE AND MODERNIZE YOUR VIEWS OF BITCOIN

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 [ ADD YOUR STATE HERE ], 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 Bechtold