Subject: File No. SR-NYSEArca-2021-90
From: Abelardo Gonzalez
Affiliation:

May. 06, 2022

Dear SEC,

I reside in West Palm Beach Florida and as an active retiree I manage our savings with my wife. We invest in ETF’s as a way to balance our risk and converting GBTC into an ETF would support our conservative strategy to grow our savings in the long-term as opposed to an speculative strategy. We are 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,
Abelardo Gonzalez