Feb. 23, 2022
Sir/Ma'am, I'm writing to express my support for the conversion of the Grayscale Bitcoin Trust to an ETF. 1. Easily accessible, existing methods of purchasing Bitcoin already exist for many citizens. Preventing a Bitcoin ETF most negatively impacts individuals who want access to Bitcoin but do not have sufficient funds outside of their retirement accounts and individuals who want access to Bitcoin but are not tech savvy or trusting enough to open accounts with crypto exchanges. Permitting a Bitcoin ETF would allow these individuals, and all individuals easier access to Bitcoin if they so desire. 2. Currently, to access actual Bitcoin exposure in a retirement account requires buying GBTC (with fluctuation to NAV and a steep premium), buying Bitcoin Futures ETFs (with fluctuations to spot and a steep premium), or setting up a Self Directed IRA (which is complicated and has high fees). Each of these options have significant drawbacks and are in no way safer than a spot Bitcoin ETF would be. Permitting a spot Bitcoin ETF would permit individuals to access Bitcoin in their retirement accounts in a much less risky way. 3. Permitting the ETF would reduce fees and encourage competition, both of which are better for consumers. 4. The SEC has already approved future's based Bitcoin ETFs (BITO and BTF for example). Futures ETFs do not provide the same protection as a spot ETF would. The futures ETFs have higher fees and do not track the Bitcoin price nearly as accurately as the spot ETF. Furthermore, the supposed concerns about Bitcoin spot ETF would also apply to futures ETFs, as the futures are derivatives of the spot. Logically it follows that a spot ETF should be permitted before the derivative of spot ETF is approved. Ironically, this was not the case. 5. GBTC trades like a closed end fund which creates swings in relation to the net asset value. This creates additional risk for investors who merely want Bitcoin price exposure. They do not want exposure to the additional risk of the swings above and below the underlying net asset value. A Bitcoin spot ETF would eliminate this risk and help those investors. 6.Grayscale has a reliable reputation and is well regulated by the SEC. It is likely that converting GBTC to an ETF would result in a net inflow of dollars to GBTC. This means a well regulated, law abiding company would play a bigger role in the Bitcoin Ecosystem. This would increase the SEC's ability to protect individuals who own Bitcoin. 7. People should be allowed to use their money as they see fit. I believe people should be able to engage in nearly any non-harmful venture and/or investment. If losses are suffered, that is part of investing in non-guaranteed ventures. Moreover, people are likely to learn lessons and be better stewards of their money in the future. We must fall before we walk, and we must walk before we run. In conclusion, allowing GBTC to convert to an ETF would reduce risk for investors, increase SEC's oversight in the space, and help protect Americans. Respectfully, Sean Egan -- Sean Egan