Apr. 22, 2022
Dear SEC, I write to you as a long-term GBTC shareholder supporting the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) to an ETF. I am aware of the enormous risks of this crypto-currency based investment vehicle. However, please recognize that even established corporate assets are affected by the same market risks humans bring psychologically-and these type risks are all that is meaningful in today's public markets. Accounting and financial performance measures are practically illusions covering the true human dynamic at play that affects almost all returns. Companies that operate to support collectibles fields are effectively the same as cryto-assets from the risk perspective-there is no underlying value past human market psychology. For instance, if you grade baseball cards (CLCT) or auction art or old cars, no tangible utility value exists in the underpinning anchors of these exchanges. By not approving my conversion, you are not protecting me, the investor - the very person you were appointed to protect. Last October, the SEC approved futures-backed Bitcoin ETFs, but continue to reject applications for spot Bitcoin ETFs. When the agency brings regulation and oversight - psychological drivers of greed and avarice are resisted. This is your mandate. The SEC was created to help - through engagement and action. Crypto assets are driven by humans, the same as traditional assets your organization routinely finds abuses within. The futures-based approvals show you accept this mandate in the most volatile and practically virtual market form that exists. Please approve or provide the practical guidance needed to approve spot ETFs like mine as well. Harm is being done by your past inaction. The discount to NAV in GBTC has been around 25%, on average, this year. Given that GBTC has about $30bn in AUM, shareholders like me are experiencing a destruction of value of around $7.5 billion. Also, without approval certain market regulating and efficiency supporting mechanisms are denied. I'm writing from Chattanooga, Tennessee, with gratitude for the opportunity to express my view and with the hope that you will approve this conversion and protect the interest of investors. Sincerely, David L. Witt, Sr.