Apr. 22, 2022
Sirs: I write in regard to the application by Grayscale Bitcoin Trust (GBTC) to convert from a trust to an ETF. I wrote in support of the application. First, my interest in the issue is first and foremost as an owner of GBTC shares. Secondarily, my interest is in the fair and proper functioning of financial markets. As an owner of GBTC, I believe that conversion to an ETF would benefit all beneficial owners of the trust. The price of my shares would more accurately track the Bitcoin price if the conversion is allowed. By contrast, the shares continue to trade at a substantial discount today in what can only be classified as opaqueness of the market. I purchased Bitcoin in the form of GBTC shares because I wanted an asset that tracked the price of Bitcoin without having to own the electronics/digital asset. Harmonizing the NAV price with the value of Bitcoin would improve transparency and openness. As an advocate of fair and properly functioning markets, I also support the proposed conversion. The SEC has expressed concern that allowing an ETF based on the spot price could lead to manipulation - however, there is even greater manipulation possible with an ETF based on the futures price, which the SEC has already allowed. Given that the SEC has already approved a Bitcoin based on the futures price, there is no good reason to prevent this proposed conversion to an ETF. In fact, there is no good reason to prevent this conversion. I urge the SEC to approve this conversion forthwith. Thank you. Very truly yours, Ed Mazlish