Subject: FILE NO. SR-NYSEArca-2021-90
From: Jim Valin
Affiliation:

May. 10, 2022

Dear Sir or Madam: 


I am writing to urge your Agency's approval of GBTC request to convert to an ETF. 


While I am only going to build a 5-10% portion of my retirement portfolio in the Crypto class, I would really like to hold that within a traditional brokerage account with my other holdings. 


I have been asked why I don't merely buy BTC through an exchange like Coinbase, Robinhood, etc. My answer is very simple..., there are no Crypto Exchanges which offer "Transfer on Death" accounts! I do not want to burden my heirs with having to suffer substantial legal fees to obtain access to the Crypto portion of my retirement funds upon my demise! For this reason (being unable to invest in the growing number of Crypto ETFs on foreign exchanges), I have been accumulating GBTC shares even though they cannot, due to their legal structure, mirror the price of Bitcoin. A very crude manner of participating in the Crypto market, but the only one currently acceptable to me. As for Bitcoin Futures..., that is not a long-term accumulation strategy..., merely a trader vehicle! 


Thank you for your consideration of this matter. I sincerely hope to learn of your favorable decision on the Graystone request in the near future. 


James L.Valin