May. 06, 2022
Dear SEC: I am 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, the SEC is not protecting me, the investor it is appointed to protect. Last October, the SEC approved futures-backed Bitcoin ETFs, but continues to reject applications for spot Bitcoin ETFs. Given that investors use both vehicles to gain exposure to the same underlying asset, me (as an investor) needs to be able to choose if I’d like direct or futures-based exposure to this asset. During CY 2022, the discount to NAV in GBTC has averaged around 25%. This discount means that the price of GBTC is less than the price of Bitcoin, the asset itself. Given that GBTC has about $30bn in AUM, existing shareholders like me are experiencing a destruction of value of around $7.5 billion. 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 with appreciation for the opportunity to express my views to the SEC and expectation that it will approve this conversion and protect the interests of GBTC investors. Sincerely, David R. Derenzo Resident State of Michigan