Subject: File No. SR-NYSEArca-2021-90
From: Randolph Benoit
Affiliation:

May. 06, 2022



Dear SEC,

I write to you as a GBTC shareholder, in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) to an ETF.

There has been a discount to NAV in GBTC this year that has averaged around 25%. 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. Conversion of GBTC to an ETF would eliminate this distortion and destruction of value.

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.

I am writing as a resident of Texas with the hope and expectation that you will approve this conversion as a measure to protect the interest of investors.

Sincerely,

Randolph Benoit