Subject: File No. SR-NYSEArca-2021-90
From: Mark Prisbrey
Affiliation:

May. 09, 2022

To whom it may concern at the SEC, 

I am a GBTC shareholder, and support the conversion of Grayscale Bitcoin Trust (GBTC) to an ETF. By not approving this conversion, you are not protecting me, the investor – the very person you were appointed to protect - but are doing damage to my portfolio. 

Last October, the SEC approved futures-backed Bitcoin ETFs, but continue to reject applications for spot Bitcoin ETFs. Given that investors use both vehicles to gain exposure to the same underlying asset, Bitcoin—from which both vehicles derive their prices—we, as investors, should be able to choose if we’d like direct or futures-based exposure to that asset. A free and open marketplace reduces opportunities for the wealthy and connected to abuse the average investor. 

Furthermore, the discount to NAV in GBTC has been around 25%, on average, this year. 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, shareholders like me are experiencing a destruction of value of around $7.5 billion. 

I’m writing from Texas. I hope that you will approve this conversion and protect the interest of investors. 

Sincerely, 

Mark Prisbrey