Apr. 28, 2022
Dear SEC, I write to you as a GBTC shareholder, in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) to an ETF. 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. Furthermore, the discount to NAV in GBTC has eclipsed 30%, this year. This means that the price of GBTC is less than the price of Bitcoin, the asset itself. This makes zero sense and actually hurts the average retail investor (me), more than anyone. GBTC is the world’s largest publicly-traded cryptocurrency fund, with hundreds of millions in daily trading volume. It holds approximately 3.4% of all Bitcoins outstanding, and is held by more than 850,000 investors, like me. I’m writing from New Jersey, with gratitude for the opportunity to express my view to you and with the hope and expectation that you will approve this conversion and protect the interest of investors. Thanks very much, Kevin O'Toole