Feb. 22, 2022
To whom it may concern, I’m writing to support the conversion of the Grayscale Bitcoin Trust (Symbol: GBTC) into a spot bitcoin ETF. The SEC's continued rejection of a spot bitcoin ETF makes no sense and is firmly in contrast to the SEC's stated goals. I will provide examples below: 1. The SEC claims their role is to protect investors. Investors want to invest in bitcoin. This is a fact. It is not the SEC's job to determine if bitcoin is a good or bad investment. If we accept this as valid, then the SEC is actively harming investors by not allowing a spot ETF. The futures ETF is clearly a worse product. The cost of rolling over futures contracts is explicitly harming investors. This would not be the case with a spot bitcoin ETF. Furthermore, the Grayscale Bitcoin Trust is trading at large discounts (varying and recently around -30%), because bitcoin can not be pulled out of the trust. This harms investors. If Grayscale is allowed to convert this trust into a spot ETF, this loss that investors are currently experiencing will disappear. Shares will revert back to NAV as investors could arbitrage the underlying asset. Grayscale is one of the largest holders of bitcoin in the world, and would be a natural first choice to approve for a spot bitcoin ETF. 2. The SEC constantly claims that, unlike the bitcoin futures market, the spot market is not regulated enough and is open to market manipulation. Logically, this makes no sense. The spot and futures markets are intertwined and trade similarly due to arbitrage. If you believe that a futures ETF is safe enough, then it stands to reason a spot ETF should be safe enough as well. 3. Spot bitcoin ETFs exist in other countries with developed financial systems. I am genuinely concerned that the United States will be left behind in the changing financial industry. This is one barrier to entry that can easily be fixed. Use me as an anecdotal example. I will invest in a spot bitcoin ETF from Grayscale. I will not invest in any bitcoin futures ETF product. 4. The SEC claims they want to prevent fraud. Wouldn't the SEC find it is easier to keep an eye on such things if the bitcoin was custodied by regulated United States based spot ETF providers, rather than off-shore providers or people holding bitcoin in anonymous wallets? Please allow Grayscale to convert their Grayscale Bitcoin Trust into a spot bitcoin ETF. Sincerely, Dustin Buckley