Subject: File No. SR-NYSEArca-2021-90
From: Bill DeLeeuw
Affiliation:

May. 18, 2022

Dear SEC, 

I am a GBTC shareholder from Oregon, writing in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) — the world’s largest publicly-traded cryptocurrency fund — to an ETF. 


Thank you for this opportunity to express my view. By approving OTCQX:GBTC conversion to ETF, you will protect me, the investor – the very person you were appointed to protect. 

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. 

Furthermore, the discount to NAV in GBTC has been around 25%, on average, this year. This means that the price of GBTC is less than the price of Bitcoin, the asset itself. Given that GBTC has about $30bn in AUM, shareholders like me are experiencing a destruction of value of around $7.5 billion. 

Please approve the proposed GBTC to ETF conversion and help remove artificial investment losses created by the prior administration's knee-jerk reaction to new and promising monetary technology. 

Thank You and Best Regards, 

William C. DeLeeuw 
Small business founder, investor, and proud cryptocurrency owner 
Beaveron, OR