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. If the SEC's goal is truly to protect the consumer, then a spot ETF should be approved. The SEC approved BITO futures based ETF is not a cost efficient solution for the retail buyer as it must incur heavy rollover costs. Currently, the GBTC product is trading at a large discount to NAV which has significantly hurt the value of investors' holdings including my retirement roth IRA. In 2022 the SEC claims the rejected spot ETF products were not 'designed to prevent fraudulent and manipulative acts and practices.' Yet, since 2017 the CFTC has had no such qualm in overseeing the CME bitcoin futures trading. This successful product has been trading for nearly 5 years with no instance of fraud or manipulation. The CME has developed and employed useful tools to help monitor the legitimate price of bitcoin since 2016 including the CME CF Bitcoin Real Time Index (BRTI) and the CME CF Bitcoin Reference Rate (BRR). These products have functioned to provide accurate real time and daily bitcoin price data for futures trading purposes. There is no reason the SEC cannot develop similar pricing tools in order to combat the market manipulation they fear. As a proud citizen of the state of Florida, I appreciate your consideration and support. I hope retail investors like myself will get the chance to invest in a fair playing field and I believe a spot bitcoin ETF approval will be a step in the right direction. Kind regards, Michael Brannon