Feb. 23, 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. GBTC currently trades at a ~25% discount to its NAV, a discount that would be almost entirely erased in a spot ETF structure. In addition to removing this discount, an ETF structure would dramatically lower fees for GBTC investors. A spot Bitcoin ETF would also give investors a way to invest in Bitcoin through an ETF structure that would directly track the price of Bitcoin (which is what those investors are trying to do). The current futures-based ETFs expose investors to tracking error relative to Bitcoin’s price, and incur significant and unnecessary costs from rolling the futures every quarter. Investors, not the SEC, should be the ones who decide whether to invest in a spot or futures based Bitcoin ETF. By approving only futures based ETFs so far, the SEC has been hurting investors rather than protecting them. The beneficiaries of the status quo are money managers raking in fees and middle men exploiting the futures roll, not investors. Jon Behar WA state resident