Feb. 17, 2022
To the Commissioners of the SEC: Please allow the conversion of the Grayscale Bitcoin Trust into an etf. Unlike previously denied spot bitcoin etf applications, the Grayscale Bitcoin Trust is already available to all investors. Grayscale has the largest holding of bitcoin and has been advocating bitcoin since the early days of bitcoin. It makes sense for GBTC to become the first bitcoin etf. Conversion to an etf would make this a better and safer product for investors. The mission of the SEC is to protect investors and to create a fair market in a manner worthy of the public's trust. The SEC will lose the public's trust by inconsistently approving a bitcoin futures etf but denying a spot bitcoin etf. The pricing for both is based on the same underlying asset so both are susceptible to manipulation. Bitcoin futures may be even more susceptible to manipulation since they are settled in dollars and actual bitcoin doesn't need to change hands. There is overwhelming support of investors for a spot bitcoin etf. Holding spot bitcoin is a better way to gain exposure as investors can just hold as opposed to having to trade futures frequently avoiding more fees. Investors understand the risk of manipulation in bitcoin but still want exposure. As bitcoin has matured with more adoption and institutional acceptance, bitcoin has been trading in almost perfect correlation to the equity markets. Thus, bitcoin is not more uniquely manipulated than equity markets. Please do not delay any further a spot bitcoin etf. Respectfully, Brian P