Subject: File No. SR-NYSEArca-2021-90
From: Denny Monroe
Affiliation:

May. 06, 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).  Approval of ETF’s to hold bitcoin directly will  open competition and likely drive the current management
fee of 2.0% down to around 0.5%, thus benefiting all shareholders.

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.   Direct exposure is more effective than futures based exposure.

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 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,

Dennis R. Monroe, CFA, CFP