Mar. 21, 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. I believe that the United States must lead in adopting Bitcoin as a legitimate investment asset class. A Bitcoin ETF that trades on the public stock exchange and subject to the same regulatory rules as other similar ETF products should be the right of every American investor. Currently, American investors seeking exposure to Bitcoin are forced to higher risk and lower liquidity exchanges outside of the normal venues accessible to broker dealers that may carry risks that an investor cannot reasonably evaluate. This is a direct result of the SEC hamstringing other legitimate forms of exposure to Bitcoin, such as GBTC, and failing to create a clear path forward for all broker dealers to provide this option to investors with regulatory clarity. The SEC should act now to legitimize GBTC as a spot ETF for Bitcoin before American investors are harmed by the SEC's inaction and an increasing number of investors who become aware of Bitcoin are forced to choose riskier alternatives. Unnecessary and unwarranted delays that hamper progress on such a critical asset further demonstrates to the world America's inability to lead on financial matters of the most importance. Further, it creates confusion among investors as no clear path on how an investor may gain legitimate exposure to such an asset within the financial regulatory framework has been provided by the SEC. The market has already spoken very clearly about Bitcoin. American investors want to fairly adopt this new asset. Time is of the essence, as many investors view Bitcoin as an inflation hedge during a period where such risks are top of mind for every American. Why should American investors be at a disadvantage compared to other countries (such as Canada) who have already taken action? The SEC's role is not to stand in the way of innovation. Each day the SEC fails to act robs Americans of their right and ability to participate freely in a critical piece of the future. Hester Pierce conveyed the absurdity of the SEC's behavior on this matter best: “I can’t believe we’re still talking about this as if, you know, we’re waiting for one to happen,” Peirce said. “We’ve issued a series of denials even recently, and those continue to use reasoning that I think was outdated at the time.” Sincerely, Ashish Rastogi