Subject: File No. SR-NYSEArca-2021-90
From: Nick Mogilnicki
Affiliation:

May. 10, 2022

Dear SEC,

I am BTC Investor living outside USA and I am in favor of approving the Form 19b-4 that NYSE Arca filed with you to convert Grayscale Bitcoin Trust (OTCQX: GBTC) – the world’s largest publicly traded crypto asset fund, with approximately $30 billion in AUM, hundreds of millions in daily trading volume, more than 850,000 investors, holding approximately 3.4% of all Bitcoins outstanding – into a Bitcoin Spot ETF.

It is impossible to comprehend how a futures ETF supports the interests of individual investors with substantial investment risks over a spot ETF. In fact, the futures ETF directly aids the institutional large players, which the SEC claims to protect individual investors from.
Several countries have already implemented a spot ETF for BTC with no adverse effects and others have adopted BTC as store of value and a payment network. Close to 300 million people around the world trust the BTC technology over the last decade with their assets. 
Comparatively, the BTC network adoption grows at a rate faster then the internet and has real chance to speed up the adoption of clean energy solutions around the world.

This year, GBTC has traded at an approximately 25% discount to its NAV, which means the price of GBTC is less than the price of its underlying assets, Bitcoin. 
With approximately $30 billion in AUM, that results in approximately $7.5 billion of trapped value from existing U.S. investors.

It is time to do the right thing and approve the a spot ETF.

Sincerely,
Mikolaj Mogilnicki