Subject: File No. SR-NYSEArca-2021-90
From: Dave Gilroy, Mg. Dir., Scale Finance LLC
Affiliation:

May. 06, 2022

Dear SEC, 


I'm a NC citizen and concerned investor. Im also a GBTC shareholder and have been for over 2 years. I'm very much in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) to an ETF.  


Please expeditiously approve this conversion. 


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 $30B in AUM, shareholders losing a lot of my retirement funds unfairly and unnecessarily.  


Thank you for considering my views.  



Dave Gilroy 
Mg. Dir., Scale Finance LLC