Subject: File No. SR-NYSEArca-2021-90
From: Karl Wolff
Affiliation:

May 22, 2022

Dear SEC,

As a citizen of the United States, I am writing to you in support of approving the conversion of 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.

Many other countries have approved spot Bitcoin ETFs and they are functioning well. The futures based ETF approved in the US is a suboptimal way for investors to gain exposure to Bitcoin. GBTC as a spot ETF is needed and overdue. 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,
Karl Wolff