Subject: File No. SR-NYSEArca-2021-90
From: Matt Peterman
Affiliation:

May. 06, 2022

 


 
Dear SEC members, 
 
I write as a shareholder of the Grayscale Bitcoin Trust, ticker symbol “GBTC”, in support of the conversion to a spot ETF.  In contrast to your communications to date, I do not think you are protecting me or other investors like me by failing to approve this conversion or other applications for a spot Bitcoin ETF.  In fact, I believe you are causing me financial harm by reducing the liquidity of an investment vehicle designed to provide said liquidity.  In addition, the current structure of the trust is such that the providers are earning a full 2.0% expense ratio in perpetuity.  If a spot ETF conversion was to be approved, the expense ratio would be eliminated further improving the economic efficiency in the marketplace, a feat I would venture to guess is very much aligned with your mission.  
Last October, you approved futures-backed Bitcoin ETFs.  The approval of a spot ETF conversion, along w/ other applications to provide a spot ETF is simply the next logical step to achieving a properly functioning market for this asset-class.   As it stands currently, the discount to NAV on the GTBC is hovering around 26%...that simply should not happen in a market of this size.  For investors like myself, that discount is eroding a nontrivial amount of our investment into this asset class for reasons completely unrelated to the value of the underlying asset.  
I’m writing from Texas, with gratitude for the opportunity to express my view as well as hope that you will reconsider and approve this conversion to protect the interests of the hundreds of thousands of GBTC investors like myself.  
 
Sincerely, 
 
Matt Peterman  
 
 
Matt Peterman, CFA
Senior Vice President - SBA Trading