May. 08, 2022
Dear SEC Commissioners: I fully support converting the Grayscale Bitcoin security, "GBTC" to a true EETF. Why? 1) This will bring make the cryptocurrency leader available to more investors, thereby stabilizing this market, compared to today. 2) The ETF will trade at a much closer match to its underlying asset value, with far smaller discounts & premiums to NAV. 3) The underlying asset value should be easy to audit and validate periodically; Just have access to the accounts holding the underlying Bitcoin. 4) There should be a smaller management fee, by simplifying the asset structure. 5) ETF-type securities based on near-term futures constantly depreciate due to the futures volatility premium that needs to be absorbed every time the near-term security matures and the managers need to roll the collateral into the next near-term futures contract. 6) More and more banks and major asset managers are accepting crypto, reducing the reliance on single-purpose crypto exchanges. Please allow GBTC to be converted to a true ETF. Bob Kmetz