May 6, 2022
Dear SEC: My name is Carlos Culebro and I write to you as a GBTC shareholder, in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC), to a Spot ETF. As you very well know, Grayscale’s GBTC fund is the world’s largest publicly-traded cryptocurrency fund and has been managed by Grayscale since 2013 (9 years). As a shareholder of the GBTC fund, there is simply no reason for not converting GBTC from being a Trust Fund to a Spot ETF. I mean come on………Grayscale is the “Grand Father” of companies offering and managing cryptocurrency products to investors. They have earned the right to have this approved and have the support and trust of 850,000-plus customers. By not approving this conversion, you are not protecting me as an investor. Having GBTC converted to a Spot ETF provides better security and stability to my investment in this product provided by Grayscale. This is something that I request and want. This is something that every GBTC shareholder wants. 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. This should be my choice as an investor as to whether or not I decide and choose to purchase Bitcoin Spot ETF shares as part of my portfolio. I am also a customer of Fidelity Investments and utilize their services for a majority of my investment portfolio. It was recently announced that employees who work for one of the 23,000 companies that use Fidelity’s 401K services will be allowed to allocate up to 20% of their portfolio to Bitcoin. I wish to continue adding Bitcoin to my retirement portfolio with Fidelity, acquiring bitcoin by way of utilizing the services of Grayscale and continuously acquiring GBTC shares as a spot ETF. In my studies of understanding cryptocurrencies in general and how to manage such assets, I feel that the combination of leveraging the purchase of Grayscale’s GBTC (as a Spot ETF) product and Fidelity being my custodial provider of my investment assets is the absolute best and secure way to own Bitcoin as part of my overall investment portfolio. 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 destructive discount of value of around $7.5 billion. I’m writing from Highlands Ranch CO, with appreciation for the opportunity to express my view and with the hope that you will approve the conversion GTBC as a Trust to a Spot ETF as soon as possible and protect my interest as an investor, both for the immediate and long term future. Thank you for taking the time to review this e-mail. With other Countries like Canada, Australia and Brazil already providing their citizens the opportunity buy bitcoin exposure by way of a Spot ETF product, it's time the United States to do the same. The United States should be viewed as a leader and innovator in technology leading financial products and services.............not a laggard. Thank you for taking the time to review my e-mail. It's time to make this happen. Sincerely, Carlos Culebro