Feb. 28, 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. The market manipulation concerns voiced by the SEC get more stale with each passing day, as the asset class matures, and Bitwise and others continue providing undeniable evidence that these concerns no longer stand on solid ground. Even if the SEC insists that market manipulation is a risk, it is incumbent upon the Commission to assign a probability to this risk, quantify the potential downside, and then weigh this against the upsides: access to an efficient vehicle that tracks the underlying with minimal variance and cost; a means for investors to securely gain exposure to a transformational burgeoning asset class without taking on unnecessary counterparty risk; and an assuaging of the growing perception that the SEC is politically motivated and is failing to apply its standards equitably. If this calculus were to be conducted objectively, I believe the Commission would conclude that continuing to deny bitcoin spot ETFs is an abject failure of its responsibility to protect American investors. As things stand, investors are not protected. A typical investor that seeks exposure to bitcoin incurs one or more of the following: exorbitant fees and costs associated with inefficient investment vehicles, significant counterparty risk, susceptibility to fraud, risks associated with self custody. The novelty of bitcoin as an asset class inherently comes with more unknowns than long-established asset classes; however, this does not justify the SEC's continued hand-waving and myopia. Americans deserve the opportunity to freely and fairly participate in and invest in this technological revolution. Sincerely, Anonymous