May. 02, 2022
To whom it may concern: I am a holder of GBTC shares bought in the open market and I am writing this note to support the conversion of GBTC to a spot price ETF tracking stock. I invest money for a family office and am limited to equity and bond investments. I use GBTC similarly to how I use gold ETFs, for diversification. I have algorithms which readily rebalance based on set correlation goals between anticipated price movements of portfolio assets in attempt to proactively minimize correlation. GBTC's behavior as a trust undermines my goal, as its erratic relationship to the spot price of bitcoin makes it harder to optimize position size. As an ETF with a smaller deviation from spot, it would be much more helpful. Media reports the SEC has concerns the spot price of bitcoin may be manipulated. From my perspective, I believe I run this risk also with gold ( which can be manipulated by governments, among others ) and with many specific equities ( as the recent meme stock fad shows ). I can't put a number to this risk in any specific case and I suspect the SEC cannot either. In my opinion, there is no rational way to decide if the risk is "too large", not only because different investors have different risk tolerances but also because of this impossibility of quantifying what the risk is. It is far better to let those of us who invest manage our own risk through appropriate position sizing rather than pretending the government can do this job for us. thank you, --Gregg Rosenberg Managing Partner, The Luckybidwell Group