May. 06, 2022
Dear SEC, I am a GBTC shareholder, in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) — the world’s largest publicly-traded cryptocurrency fund — to an ETF. By not approving this conversion, you are not protecting me, the investor – the very person you were appointed to protect. I've been buying GBTC to get BTC exposure in my retirement plan. As you know, retirement plans typically don't allow purchase of BTC into IRAs or 401ks etc. This is the only way to have some exposure in my retirement portfolio. 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 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 $30bn in AUM, shareholders like me are experiencing a destruction of value of around $7.5 billion. I’m writing from Birmingham, MI to express my view and with the hope that you will approve this conversion and protect the interest of investors, especially people like me who have GBTC exposure in their retirement portfolio. Sincerely, Regards, David Wassmann