Apr. 23, 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 an ETF. A dedicated Bitcoin fund allows me to hold Bitcoin in accounts where it is not possible for me to directly buy bitcoin. By not approving this conversion, you are not protecting me, the investor – the very person you were appointed to protect. Last October, you approved futures-backed Bitcoin ETFs, but continue to reject applications for spot Bitcoin ETFs. Given that investors use both vehicles to gain exposure to the same underlying asset, Bitcoin—from which both vehicles derive their prices—we, as investors, should be able to choose if we’d like direct or futures-based exposure to that asset. In fact, I would argue that allowing direct exposure to the underlying asset in an ETF is more-appropriate for most individual investors than only allowing exposure via a futures-based ETF. Furthermore, the discount to NAV in GBTC has been around 25%, on average, this year. This means that the price of GBTC is less than the price of Bitcoin, the asset itself. Given that GBTC has about $30bn in AUM, shareholders like me are experiencing a destruction of value of around $7.5 billion. Finally, by not allowing this conversion, you are placing US investors at a global competitive disadvantage and are falling behind globally in this important area of new technology. I’m writing from Kansas, 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, Josh Goodmanson