May. 06, 2022
Dear SEC, I write to you as a GBTC shareholder, 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. 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. Please treat investors with the respect we deserve. International markets for Bitcoin are very mature with excellent liquidity and access for investors, including US investors. We know what we're getting into. There is more information than ever about the opportunities and risks presented by investing in Bitcoin. There are WAY more high quality educational resources for Bitcoin investing than there are for esoteric strategies and derivatives products that are also available through ETFs today. Why can I buy a 3x leveraged ETF that shorts the entire stock market, which historically would be a terrible choice for most investors over the long term, but I can't get a Bitcoin ETF, which historically would have been a very lucrative choice for most investors over the long term? The current regulatory stance creates a situation where 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. I’m writing from New York, 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. Respectfully, Brandon