Feb. 22, 2022
Dear Sirs/Madams, As a past and potential future customer of the Grayscale Bitcoin Trust GBTC, I would like to strongly advocate for its conversion to an ETF. Grayscale Bitcoin ETF would provide a cost effective and easily navigable way for retail customers to participate in the crypto space. Given the limitations of the "Trust" regulations and cost structure, the current pricing differential to the spot Bitcoin price is a hindrance and an additional cost that retail clients have to bear. While the regulatory authorities have a mandate to protect the public, they also have a responsibility to allow financial opportunity to non accredited investors to access crypto products through regular brokerage accounts. The potential manipulation on crypto exchanges are issues to work through and provide the regulation framework to allow for spot crypto ETF products in the USA. The BTC/ ETH futures and the futures based crypto ETFs all have contracts that expire to the same spot price set on the crypto exchanges so any manipulation is across the spectrum of products. The price differential of the GBTC "Trust" to the spot is over 20% as of today, and a much larger impact on the average customer than any possible manipulation on US based crypto exchanges. Well connected and financially well-to-do clients have the recourses to access crypto through a number of cost effective platforms in the USA and internationally. The retail customer base does not have the same access pathways and a spot priced ETF is the most cost effective path to access returns from future innovation in the space. It is difficult to understand how a spot settled ETF is riskier than a futures based ETF that settles at the same spot price. Customer protection can be accomplished by education and proper disclosures as done with many financial products. Considering that regulators have provided guidance and approvals on multiple 3X leveraged ETF's and the current GBTC "Trust" structure, my expectation is that regulators can approve a crypto spot ETF with sufficient protections for the retail customer base. Other nations have approved physical ETFs without obvious problems and it is time for our regulators to work through issues to provide fair opportunities to our retail customers and convert GBTC to an ETF structure. Thank you, Gus Tsahas NYC