May. 06, 2022
Dear SEC, As a GBTC shareholder, I am writing in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) to an ETF. Last October, you approved futures-backed Bitcoin ETFs, but continue to reject applications for spot Bitcoin ETFs. I strongly disagree with Chairman Gensler’s position on a spot Bitcoin ETF to date, and believe the refusal thus far to approve a spot ETF stems more from bureaucratic agendas, special interest accommodation favoring traditional finance power brokers like Goldman Sachs and JP Morgan Chase. Given that several other international exchanges, including Canada, have already approved spot Bitcoin ETFs the US has seen dollars flow overseas to find the investment vehicles that would otherwise make perfect sense to domicile domestically. An approved futures-backed BTC ETF without a corresponding spot version is largely unprecedented, and very much stands in contrast to narrative about a spot ETF that are based on risk concerns. Futures-backed ETFs are still based on the underlying security, but, in fact, have GREATER risk associations. GBTC is the world’s largest publicly-traded cryptocurrency fund, with hundreds of millions in daily trading volume. It holds approximately 3.4% of all Bitcoins outstanding, and is held by more than 850,000 investors, like me. I appreciate the opportunity to express my view to you and with the hope and expectation that you will approve this conversion and protect the interest of investors, institutional and retail alike. Regards, Gregory D. California