Grayscale Investments appears to be inching closer to converting its flagship fund – the Grayscale Bitcoin Trust (GBTC) – into a spot Bitcoin ETF.

In a Nov. 20 memo from the U.S. Securities and Exchange Commission’s (SEC) special counsel Edward Cho, senior executives at Grayscale met with the securities regulator’s Division of Trading and Markets. 

The discussion was centred around NYSE Arca’s proposed rule change to list and trade shares of GBTC under NYSE Arca Rule 8.201-E.

Included in the list of the meeting’s attendees were Grayscale CEO Michael Sonnenshein and CFO Edward McGee, along with attorneys from the law firm Davis Polk.

Scott Johnsson, a former Davis Polk attorney and GP at Van Buren Capital, shared a filing that detailed that Grayscale had entered a Transfer Agency and Service Agreement with BNY Mellon.

Bloomberg ETF analyst James Seyffart noted that the agreement was one that would have been required down the road to GBTC’s potential conversion into an ETF, but it did not necessarily say anything about the timing of the ETF approval.

Earlier this week, the SEC delayed its decision on spot Bitcoin ETF approvals from Global X and Franklin Templeton, in what has become a recurring theme around this particular topic.

Still, many market participants remain optimistic that things will be different this time around, especially with heavyweights like BlackRock in the ring, and some ETF analysts estimate a 90% chance of a spot Bitcoin ETF approval by January.