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. Grayscale Bitcoin Trust is already the largest bitcoin investment fund. However, as a closed end fund, it has a high 2% fee. Additionally, the fact that the fund is currently trading at a 25% discount to NAV demonstrates this is a much inferior product for investors than a spot ETF would be. Conversion to a spot ETF would mitigate both those issues. Finally, a spot ETF would provide comparable access to the underlying asset as buying bitcoin on the spot market, which is poorly regulated (unregulated in some cases) market that exposes retail investors to significant risk (loss of asset, scams, failure of custodian, etc.). Approval of a spot ETF would reduce risk to investors – not increase it. The SECs function is to protect investors. Approving a futures ETF which is far riskier and opaque for retail investors than a spot ETF while denying approval of a spot ETF runs counter to that objective. Sincerely, STEVEN MOHR COO, VIRTUAL-Q