May. 04, 2022
Dear SEC, I write to you as a shareholder, in support of the conversion of Grayscale Bitcoin Trust (GBTC) — the world’s largest publicly-traded cryptocurrency fund — to an ETF. By not approving this conversion, you are not protecting investors like me, whom 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 net asset value (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 $30 billion in assets under management (AUM), shareholders like me are experiencing a destruction of value of around $7.5 billion. I’m writing from Lutherville, Maryland, 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, Justin Brill