Subject: ​File No. SR-NYSEArca-2021-90 (​I support Converting ​GBTC into an ETF)
From: Dr. Alfred Wirth
Affiliation:

May. 09, 2022

Dear SEC,

I'm writing as a Grayscale Bitcoin Trust shareholder, in support of the conversion of the Trust into an ETF. October 2021 you approved futures-backed Bitcoin ETFs, but you continue to reject applications for spot Bitcoin ETFs. I prefer direct exposure rather than using options and futures in all my investments. Therefore I'd like an ETF representing an investment in "real" Bitcoin, Etherium, and other major cryptocurrencies so I can conveniently buy them on a stock exchange rather than relying on some sort of wallet. While I thought I could do so by buying GBTC, the Trust has an unusually high management fee and also a price which varies excessively from its underlying net asset value, sometimes over 25% while my usual ETF investments generally stay within a few percent of NAV. I understand that the conversion of GBTC into an ETF would reduce the fees a bit and, more importantly, likely keep the quoted price closer to the NAV since the underlying assets could be bought or sold by the managers.

Thank you for this opportunity to express my views, Dr. Alfred Wirth