February 7, 2022
I have read the SEC's comments on this matter with interest.
1. Ownership of Bitcoin in its private key form by individuals and small businesses does carry a small risk of loss. If the private key combination is lost, the asset is locked forever. Professional management of private keys (as is the case with Grayscale's Bitcoin Trust) is vastly safer for the public. ETF approval will expand this safety to greater numbers of persons.
2. Without a spot ETF of the underlying Bitcoin asset, any trust or holding company valuation can \"float\" against the underlying Bitcoin value--again, not safer for the public. This has already created a speculative market on top of the price market for Bitcoin.
3. If the US doesn't approve a spot Bitcoin ETF, US investors will continue to flow funds into other ETFs already approved (or soon to be approved) in other nations, such as Canada.
Respectfully, the SEC should proceed with approving the rule change and allowing Grayscale to convert GBTC to an ETF.