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. BTC has matured to become a major investment category for scores of millions around the globe, and the laggard US regulations are holding Americans back from a popular and needed form of investing in this asset class. There are multiple licensed exchanges that now operate under the eye of financial regulators which provide investor protections. The world is moving ahead and the SEC is risking giving up American leadership in this field, losing business and prestige in the face of advancements in financial regulation in Canada, the European Union, and Great Britain. Not approving a spot-ETF is hurting U.S. investors by forcing investors to use unlicensed, inadequate, or inferior alternatives, which ultimately increases their risk. A spot-based ETF will meet the needs of retail investors who are not comfortable using future-based products, and the very large number of institutional investors and funds who would like direct exposure to BTC and whose charter requires that they invest in SEC approved funds. Further, approving only a futures-based ETF and not a spot-based ETF is non-sensical as a futures-based ETF is ultimately influenced by the underlying asset and ultimately carries similar risk criteria as a spot-based ETF would. Your delay in approving this Grayscale GBTC spot-ETF is hurting American investors and retirees, and putting them at risk by forcing them to use unlicensed, inadequate, or inferior alternatives. This is not good policy and restricts the investment choices of many citizens. I urge the SEC to approve this rule change immediately. Sincerely, Patrick Neal