May. 07, 2022
To Whom It May Concern: I am writing as a shareholder in favor of approving the Form 19b-4 that NYSE Arca filed to convert the Grayscale Bitcoin Trust (GBTC) into a Bitcoin Spot Exchange Traded Fund (ETF). GBTC currently trades at a discount to its NAV and a conversion to an ETF, with its creation and redemption mechanism, would cause the shares to better reflect NAV and protect the many investors currently holding GBTC. The SEC approved several futures-based Bitcoin ETF's in 2021, but has subsequently disapproved several spot-based Bitcoin ETF's. I believe investors should have the choice between investing in futures-based Bitcoin ETF's and physical Bitcoin ETF's, but limiting investors' choice to ETF's based on futures seems inconsistent with the SEC's goal of providing transparency for investors. Futures are complex instruments and prices of ETF's based on futures have greater potential to diverge from the price of the underlying instrument than prices of physical ETF's, as occurred with the futures-based US Oil Fund did in March 2020. Futures-based ETF's are useful instruments for investors who understand the mechanics of the futures markets, but can lead to misconceptions for investors if they believe they are investing in the underlying asset. I hope the SEC approves GBTC's conversion to a physical ETF, which would allow investors a choice over which type of product best meets financial goals and thereby support the Commission's core mission of protecting investors. Thank you for your time and consideration. Sincerely, Paul Emata Wallingford, PA