May. 07, 2022
Dear SEC (sent to rule-comments@sec.gov), I write to you as a friend of someone who is a GBTC shareholder and as a Bitcoin owner myself, 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. Rather, you are harming my financial standing and prospects. I suspect that few or none of you actually understands Bitcoin. If that is correct, it is incumbent upon you to learn. Please do so, and find a way to demonstrate to the public that you have knowledge of the underlying asset that you regulate. 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 my friend are experiencing a destruction of value of around $7.5 billion. I’m writing from MA, with gratitude for the opportunity to express my view and with the hope that you will approve this conversion and protect the interest of investors. Sincerely, Robert Myers (73 year old retiree)