Subject: File No. SR-NYSEArca-2021-90
From: Bill Spurr
Affiliation:

May. 06, 2022

To Whom it May Concern, 


Please convert GBTC to an ETF for the following reasons - 


The ETF would more effectively track the price of Bitcoin, effectively eliminating discounts and premiums If GBTC shares are trading at a discount to NAV, all else being equal, they will increase in value upon conversion 


If GBTC shares are trading at a premium to NAV, all else being equal, they will decrease in value upon conversion
Grayscale has committed to reducing management fees for GBTC
GBTC would be uplisted from OTCQX to the NYSE Arca