Apr. 22, 2022
Dear SEC, I write to you as a GBTC shareholder (and founder of a SEC registered investment adviser), in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) to an ETF. Whether crypto currencies become mainstream (or not) as an asset class, investors should have the right to choose. I also recognize that your job is to provide safeguards for investors but not approving GBTC as an ETF may actually have the opposite effect to what you are considering. Conversion to an ETF should enhance the market and create more efficiencies in pricing – that is a good thing for investors overall. In regards to public safety, not allowing vehicles like the ETF conversion to happen does push many investors (particularly novice investors looking to get a ‘lottery ticket’) into more esoteric structures/products that actually have more risk given the illiquidity, lack of pricing transparency, and complexity of accessing and trading in crypto currency. I think opening up ETFs in this space would actually help prevent more fraud as it would pull people back into regulated markets that have oversight. While there are inherent material risks for investing in cryptocurrencies, there is also that same risk in buying speculative stocks so I don’t see approving this ETF as anything more inherently risky than what investors already have exposure to in the public markets. Like all things, investing prudently should be the mandate but free markets are always going to be ripe for speculation by some. I’m writing from Arizona and hope that you will approve this conversion as I do think it will actually enhance investor protections by bringing these investors back into regulated market products such as ETFs. Specifically for GBTC investors, there would immediate benefit from such a change so I am not sure how not approving the conversion protects the public’s interest? I hope you consider these points when making your decisions. Sincerely, Todd Douma