Feb. 24, 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. It is high time the Commission approve a spot bitcoin ETF in the US. There are now at least a dozen futures-based ETFs for bitcoin, which are far inferior for investors due to the embedded cost of rolling futures contracts. Meanwhile, the existing investors in Grayscale's Bitcoin Trust (GBTC) are subject to $7 billion dollars of NAV impairment, due to the flawed structure of the trust compared to an ETF. The lack of a spot ETF is not preventing anyone who really wants to invest in bitcoin to do so. But it is causing material harm to investors by the continued GBTC impairment as well as funnelling new money to inherently inferior futures-based ETFs or to Canadian or other vehicles outside the US. By now there is ample historical data to demonstrate how closely the CME futures contracts track the spot market (and in fact as BitWise's research has shown, lead the spot market most of the time). The SEC's current position of allowing a futures-based ETF, but not a spot bitcoin one, is arbitrary and capricious, and the SEC should rectify that situation at its earliest possible opportunity. Respectfully yours, John Pfeffer