Subject: File No. SR-NYSEArca-2021-90
From: Karen Banks
Affiliation:

Jun. 16, 2022

I am an individual investor residing in Texas and I am in favor of your approving the form 19b-4 that NYSE Arca filed with you to convert Grayscale Bitcoin Trust, symbol GBTC, into a Bitcoin Spot ETF.  As you know, GBTC is the world's largest publicly traded crypto asset fund with more than 850,000 investors holding at least 3.4% of all Bitcoins. 
  
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 representing billions of dollars in trapped value from existing investors.  If the fund is converted to a Spot ETF, the price of the fund would revert to approximately the Spot price of Bitcoin.   


I do not understand why the SEC has allowed a Bitcoin Futures ETF but rejected a spot BTC ETF.   


If Grayscale is allowed to convert the existing Bitcoin Trust into a spot ETF I believe the following would occur: 


1.  Grayscale will reduce their management fees. 


2.  The ETF will more efficiently track the price of BTC effectively eliminating discounts and premiums. 


If you will approve the conversion of Grayscale Bitcoin Trust into a Bitcoin Spot ETF, those of us who would like some Bitcoin exposure in their portfolio, but do not want a Bitcoin Futures ETF, would have a less expensive and more price efficient choice than what we have at present. 


Thank you for your consideration. 


Sincerely, 


Karen Banks