Feb. 22, 2022
Dear 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. The SEC has a history of balancing innovation and consumer protection to which I am very thankful. A futures-based ETF, although very liquid, does not track the spot price of the underlying asset consistently over time and the investor is subject to the NAV erosion due to cost of rolling the contracts. This is not only true for Bitcoin, but for most commodity ETFs that use futures contracts to track the price of oil or other natural resources. Futures based ETFs are also more likely to distribute short term or long term capital gains which can be detrimental to small investors. In contrast ETFs like GLD track the spot price of gold and do so cost effectively and efficiently. Gold is certainly harder to transport than BTC in the event of creation/redemption yet the market has worked with custodians, trustees, auditors, regulators and authorized participants to make tickers like GLD and SLV a reality. My ask is that you allow the same features and benefits for a spot Bitcoin ETF. Thank you. Respectfully, Sam