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

Apr. 23, 2022

 


***[PLEASE CUSTOMIZE WITH YOUR VIEWS ON THE CONVERSION, INCLUDING WHICH STATE YOU RESIDE IN – THANK YOU FOR YOUR SUPPORT]*** 

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 hindering me more than you are protecting me, the investor – the very person you were appointed to protect. I buy appropriate position sizes of these volatile assets but I 
need to be able to move them easier and with the transparency an ETF provides. I need your help to do so.

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. I already own 30+ cryptos used for stores of value, DeFi, metaverses, NFTs and smart, trustless contracting despite being a baby boomer! A GBTC ETF would be good for me.

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 Kentucky, 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,
David J Zoeller