Mar. 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…several reasons come to mind: Many investors lack the technical expertise to custody their own Bitcoin properly, and furthermore, many do not even want to do that. A properly managed Bitcoin ETF should provide the average investor better custody security. Investors in the US that are currently wanting Bitcoin exposure in an existing brokerage or IRA account usually end up in GBTC, which has high fees and does not trade at NAV, adding another risk. GBTC fees are high and should be lowered upon conversion to an ETF, which would be very good for the investors. While Bitcoin is volatile, there are lots of other ETFs that are arguably more volatile and risky, like the 3X leveraged ETFs and the “rolling futures contract” types of ETFs / ETNs (i.e. on the VIX or natural gas). These ETFs tend to lose value vs the underlying asset they are tracking and some are virtually guaranteed to lose money over the long term. zA well-managed Bitcoin ETF would be volatile, but it should track the price of Bitcoin very closely. From the standpoint of the government, I believe a Bitcoin ETF would also be much easier to regulate and tax. These ETFs would represent the Bitcoin investments of many investors in one entity as opposed to each investor separately having custody of their own Bitcoin. This should make regulating these accounts and the tracking of Capital Gains much simpler as you would have the help of the large, established custodians. I own some GBTC in an IRA and it’s very frustrating to see it trading at a discount. It would be nice to be able to make trades at NAV and not have to contend with the discount risk. Thank you, Brian H