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

May. 11, 2022

Hello, I live in Maine and have been a long term investor in GBTC. Please process the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) to an ETF. By not approving this conversion, you are not protecting me, the investor – the very person you were appointed to protect.

Seriously, what’s up with that? I respectfully take this opportunity to remind you whom it is you actually work for.

I am requesting you respond back to me within 2 weeks to explain why you are not protecting me. 

Last October, you 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. 

As I know you are aware - the discount to NAV in GBTC has been around 25%, on average, this year. So the price of GBTC is less than the price of Bitcoin, the asset itself. As such, we shareholders are experiencing a destruction of value of around $7.5 billion.

I’m writing from Maine with gratitude for the opportunity to express my view and with the hope that you will approve this conversion and protect the interest of investors. 

Sincerely,

Mark Durgin