Feb. 22, 2022
Hi SEC.GOV Rep: I have a material amount of my retirement in Grayscale GBTC fund. I want to add my comment as to why this fund should be allowed to be converted to an ETF based on bitcoin price. I purchased the vast majority of my holdings over a year ago when because “accredited investors” were buying into the fund a lot as both a trading vehicle and for investment. Because of the way it was sold, it allowed the early investors to receive the premium the fund was charging while investors like me paid for that premium when we bought the shares. In itself that was not bad and I knew I was doing so. I also was thinking that the premium may stay and be recouped when I sold. After early investors (mostly WS Accredited investors) sold out the Premium changed to a discount where it has remained and increased to something like 25% which it is now. If I were to sell my GBTC shares and buy real bitcoin, a number of things would happen: I would sell the shares I paid a premium for, at a discount. This would result in the neighborhood of a loss of 40%. The 15% premium and the 25% discount for each share, so roughly 40%. So the investment that should be making me a huge amount of money for living and retirement would almost be cut in half because I am not an early Wall Street investor given privileged status. This is exactly the unfair situation that retail investors constantly find themselves in when dealing with Wal Street. By allowing the GBTC fund to be converted to an bitcoin ETF, the discount would very quickly disappear and the GBTC fund would approach close to the spot price. This would result in the 25% discount mentioned in b) to be reduced to 2% or something like that. I would still be responsible for the 15% premium that I chose to purchase when buying the GBTC at the beginning, as I should, since it was my decision. I would also probably choose to leave my money in GBTC ETF since it would be fair operating ETF tied to the spot price of bitcoin. If the GBTC fund is not allowed to become an ETF, I will probably accurately determine that I cannot get a fair deal buying SEC approved financial vehicles and I will sell the GBTC fund, incur the nonethical 25% discount (tax), and remove every cent of those GBTC purchases and buy bitcoin proper and hold them outside the banking system in a self-custody situation. I see no reason to be part of a investment environment where I am mined by Wall Street and charged almost the 35% discount penalties, especially when my investment decisions were good. It was just the investment vehicles were faulty and not fair. Thanks for soliciting and allowing me to submit these comments Thanks Michael Rudinsky