Feb. 27, 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. My rationale is as follows: 1) Your mandate is investor protection. By restricting the conversion of GBTC to a spot ETF, you aren't protecting investors. GBTC is already a publicly available security. Because of the lack of a spot ETF, GBTC can charge exorbitant 2%+ fees on my capital and the fund trades at a significant discount (10%+ vs. fair value). What are you protecting me from by restricting a spot ETF when (a) I can already buy GBTC, and (b) my capital in GBTC is impaired purely because of the SEC's actions (or lack thereof) with respect to a spot ETF. 2) Other G20 nations have spot ETFs (Canada, etc.). Why am I as a U.S. citizen, unable to purchase a spot bitcoin ETF when citizens of other countries that purport similar levels of democratic freedom and financial market innovation able to purchase a similar instrument? 3) You already approved a futures ETF. A futures ETF moves very similarly to a spot ETF on a downswing but the futures ETF costs investors significantly more over the long haul due to futures carrying costs. How am I better protected buying a futures ETF or GBTC as it currently exists? The answer is I am not protected when it comes to base case investment returns - I'm worse off under the status quo. Please consider all of the above in your decision and please do not factor in political motivations regarding regulating the rest of crypto in your decision. I am fully supportive of the SEC's mission to rein in the rest of the crypto landscape, but at this juncture, the SEC's arguments against a spot ETF are not sufficient to justify further delays. The only rational conclusion is that the SEC is withholding the spot ETF as a club to rein in the rest of the crypto industry - the better approach would be to show good faith by approving a spot ETF and then continuing to push for a needed regulatory framework for the rest of crypto. In case it's helpful for your records I reside in Utah. Thank you for all your great work - and I do mean that. Sincerely, Jake Keator