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

May. 11, 2022

Dear SEC,

I am retired and looking for ways to diversify from equities 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.

I am a conservative investor and do not venture beyond bitcoin in the crypto space.  The integrity of bitcoin, including limited supply and quality of the asset, is attractive to me for a small portion of my investments. Having an ETF would make it so much easier to participate in this asset versus buying bitcoin directly, which I will leave to the younger investors.


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.

Sincerely,
Mark James