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

May. 17, 2022

Comment regarding Grasyscale's desire to change the basis of their Bitcoin Trust (OTCQX: GBTC) 


GBTC being futures-based is okay, but not allowing a spot-based alternative is somewhat problematic emphasising a resultant Net Asset Value discount. I would prefer the creation of an additional spot-based alternative and that current holders of GBTC would be able to select how they wish their own holdings to be shifted between the two with no transaction costs to the retail holder (with a default result being a 50%-50% split). 


David G. Maylum