Subject: File No. SR-NYSEArca-2021-90
From: Clare Moxley
Affiliation:

May. 06, 2022

 


Good day, 


I am writing in support of Grayscale's effort to convert GBTC into an ETF. I hold GBTC as part of a diversified, index-heavy ETF portfolio. My preference, as a follower of John Bogle's philosophy of investing, is to have a diversified, index-heavy LOW COST portfolio. At this time, with a 2% management fee, GBTC does not fit the mold of "low cost". 


I hold it anyway because I believe that digital assets, over time, will be a valuable component of everyone's investments. My allocation to digital assets comprises less than 8% of my total portfolio. I take a long term view of these assets and am not "shooting for the moon". In light of this, the current GBTC management fee of 2% is a substantial drag on performance. 


In addition, as currently structured, GBTC is prone to trading at prices removed from the underlying asset's market value. This also rubs me the wrong way as a Boglehead investor, since my purpose in using ETFs is to hold products that track closely to the target asset class. 


Converting GBTC to an ETF would be beneficial to retail investors like myself who value reasonable management fees and instruments that fairly track their intended asset class. 


Thank you for your time, 
Clare 


Clare Moxley, EA, CAA 

Kimberley Tax Service