Apr. 24, 2022
Dear SEC, I write to you as a GBTC shareholder, in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) — the world’s largest publicly-traded cryptocurrency fund — to the first spot Bitcoin ETF in the US. Last October, a futures-backed Bitcoin ETF was approved, but applications for spot Bitcoin ETFs continue to be delayed. Given that investors use both vehicles to gain exposure to the same underlying asset, Bitcoin—from which both vehicles derive their prices—we should be able to have the option for direct or futures-based exposure to that asset. As you may know, the discount to Bitcoin NAV in GBTC has been around 25%, on average, in 2022. This means that the price of GBTC is less than the price of Bitcoin, the underlying asset. Hopefully, conversion to spot ETF will resolve this discount in an equitable way for current shareholders. It seems since ETF structures and laws already exist in the US, making this conversion shouldn't be troubling. I’m writing from North Carolina, 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, Edward Dorman