May. 06, 2022
Dear SEC, I write to you as a former investment industry professional; Series 7, 6, 3, and 63 licensee; and current GBTC shareholder, in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) to an ETF. By not approving this conversion, you are not protecting me nor my fellow investors. 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, investors should be able to choose direct or futures-based Bitcoin exposure. 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 destruction of value of around $7.5 billion. Bitcoin has proven its ability to be a means of asset preservation and store of value over its thirteen years of existence. I’m writing from Delaware, 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. Thank you for your time and consideration. Sincerely, Jeffery H. Gibson, M.B.A. Coldwell Banker Resort Realty