Subject: File No. SR-NYSEArca-2021-90
From: Rodrigo Santamarina
Affiliation:

May. 06, 2022

Dear SEC, 

I’m sure you will be receiving several emails with the information below from other concerned shareholders and citizens. 


I at first was skeptical of Bitcoin and thought it was a danger to my investments and finance. That was before I actually spent the time to understand it. I really found that until I spent at least 10hrs of research, I had not really understood its fundamental efficacy in protecting wealth for my family and friends. I thought the technology and leadership of it would be corruptible, until I realized that could not be farther from the truth. 


As I learned more, I see it as a wonder of technology and governance which provides voluntary and opt-in access financial protection. 


Unfortunately, many agencies and individuals who currently with seemingly good intention, are seeking to protect me and my investments have not yet done the research needed to fully understand this technological, financial and humanitarian opportunity as I have and are instead keeping me from thriving financially. 

I write to you as a GBTC shareholder, in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) 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, existing shareholders like me are experiencing a destruction of value of around $7.5 billion. 

GBTC is the world’s largest publicly-traded cryptocurrency fund, with hundreds of millions in daily trading volume. It holds approximately 3.4% of all Bitcoins outstanding, and is held by more than 850,000 investors, like me. 

I’m writing from California, with gratitude for the opportunity to express my view to you and with the hope and expectation that you will approve this conversion and protect the interest of investors. I know many others with the same opinion. 

Sincerely, 

Rodrigo Santamarina