Apr. 07, 2022
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Dear SEC, I’m writing in support of the conversion of Grayscale Bitcoin Trust (Symbol: GBTC), the largest physical Bitcoin fund in the world, to the first Spot Bitcoin ETF in the United States. As time progresses it has begun to look somewhat farcical that the SEC is onboard with Bitcoin futures-based ETFs registered under both the '33 and '40 securities acts but not an ETF based on the underlying physical Bitcoin market. The Bitcoin futures on the CME would not have a pricing mechanism if not for the trading of the underlying physical bitcoin asset. Beyond that, the SEC is short changing investors looking to add Bitcoin exposure to their portfolios by forcing them into futures-based ETF products where they are subject to slippage and disconnected performance against the underlying spot due to the nuances of rolling futures contracts forward. The best time to correct this oversight would have been when the agency first allowed futures-based Bitcoin ETF products to trade, but the second best time to correct is now. Sincerely, Andrew Jarmon