Subject: File No. SR-NYSEArca-2021-90
From: David Campano
Affiliation:

May. 15, 2022

Like many others who have submitted a comment on converting GBTC to an ETF, I agree with the following 3 points that have been asserted numerous times in prior comments: 


1. Bitcoin is easy to hold as a Physical ETF 
2. Investor's performance suffering due to the cost of using/rolling futures contracts (5-15% cost) 
3. Futures contract results can be skewed due to the emotions linked to a somewhat volatile commodity 


The fact that GBTC has been unable to actually keep pace with the underlying commodity price movements has led to (especially smaller) investors who may be trying to use bitcoin as a hedge or component of a well diversified portfolio to have lagging results. Considering many of these investors have a large percentage of assets in qualified retirement accounts, they have no option other than GBTC for their traditional brokerage/retirement savings accounts if they wish to get exposure to the asset class. Considering the aforementioned lack in comparable performance compared to BTC itself, it would be more of a harm to investors to keep "tying one hand behind their back" by being forced to use a less efficient solution. 


Thank you for your time and consideration on this matter. 


David Campano 
GBTC Shareholder 
Aurora, CO