Subject: File No. SR-NYSEArca-2021-90
From: Doug Bercow
Affiliation:

May. 06, 2022



Dear Sir or Madam,

I am writing to you as a holder of units in the Grayscale Bitcoin Trust (GBTC).

I am an individual investor who has owned units in the trust for the past 3 years.

I have found GBTC to be a very convenient way to hold Bitcoin without the hassle of managing digital keys, which for many individual investors (especially non-technical individuals) is challenging and risky (i.e., loss of keys). Thus, I think there is value that GBTC brings to the table for individuals (and institutions, too). However, there are aspects to the trust structure that I think are not as efficient as the ETF structure, causing it to trade at a discount or premium to the underlying price of Bitcoin.

I ask you to proceed forward in working with Grayscale to work with the SEC to convert the GBTC to an ETF format so that it can more efficiently track the underlying price of Bitcoin, without premiums or discounts.

Many thanks and regards,
Doug Bercow
Menlo Park, CA