February 10, 2022
Dear Commissioners:
It is high time the commission approve a spot bitcoin ETF in the US. There are now at least a dozen futures-based ETFs for bitcoin, which are far inferior for investors due to the embedded cost of rolling futures contracts. Meanwhile, the existing investors in Grayscale's Bitcoin Trust (GBTC), of which I am one, are subject to $7 billion dollars of impairment from NAV, due to the flawed structure of the trust compared to an ETF. The lack of a spot ETF is not causing anyone who really wants to invest in bitcoin to do so. But it is causing active harm by the continued GBTC impairment as well as funneling new money to inherently inferior futures-based ETFs, or to Canadian or other offshore vehicles. By now there is ample historical data to demonstrate how closely the CME futures contracts track the spot market (and in fact as BitWise's research has shown, lead the spot market a majority of the time.) The SEC's current position of allowing a futures-based ETF, but not a spot bitcoin one, is arbitrary and capricious, and the SEC should rectify that situation at its earliest possible opportunity.
Respectfully yours,
Ben Davenport