May. 08, 2022
Dear SEC, I am a Michigan resident, a retiree, and a GBTC shareholder. I support the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) to an ETF. I want a small exposure to Bitcoin in my IRA’s in addition to some direct ownership through cryptocurrency exchanges. For one reason, trading via my brokerage account is more convenient. For another reason, trusts and crypto-exchanges have higher fees than typical ETFs. But the main reason I support the conversion is that shareholders' risk calculations are unnecessarily complicated by the trust structure. ETFs nearly always trade at their NAV, trusts nearly always don’t. Deviations from NAV are a standard feature of trusts with a fixed number of shares. The discount to NAV in GBTC has been around 25%, on average, this year. That is, current regulations distort GBTC’s ability to reflect the actual Bitcoin market and cost investors more. You are not protecting me by stymying the GBTC conversion. Thank you for the opportunity to express my view. I hope that you will approve this conversion and protect the interest of investors. Sincerely, Duane Hershberger Plainwell, MI