May 6, 2022
Dear SEC, I write to you as a GBTC shareholder, in support of the conversion of Grayscale Bitcoin Trust (GBTC) to a Spot ETF. By not approving this conversion, you are not protecting me, the investor. 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. When I originally purchased GBTC the discount was approximately 2%. This is hurting me and many investors and can be remedied by the SEC through spot ETF approval. I appreciate the opportunity to express my view and with the hope that you will approve this conversion and protect the interest of investors. Sincerely, Ben Liberty