Feb. 22, 2022
Dear COMMISSIONERS/SEC, I’m writing to support the conversion of Grayscale Bitcoin Trust (Symbol: GBTC), currently the world’s largest Bitcoin fund, to the first Spot Bitcoin ETF in the United States. 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. We, the existing investors in Grayscale's Bitcoin Trust (GBTC), are subject to multi-billion dollars of impairment from NAV, due to the flawed structure of the trust compared to an ETF. Not having a US spot ETF is causing harm to those who want to invest in Bitcoin by the continued GBTC impairment as well as funneling new money to inherently inferior futures-based ETFs, or to Canadian or other offshore investments. 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, Suheil Khuri