May. 06, 2022
Dear SEC, I am a GBTC shareholder, and I support the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) to an ETF. By not approving this conversion, you are not protecting me, the investor – the very person you were appointed to protect. This doesn’t make sense to me and requires your exigent action. Last October, you approved futures-backed Bitcoin ETFs, but continue to reject applications for spot Bitcoin ETFs-this is extremely strange to me. 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. Choice is a principle that America is founded on. Furthermore, the discount to NAV in GBTC has been around 25%, on average, this year. This is a huge delta. It means that the price of GBTC is less than the price of Bitcoin, the asset itself. Given that GBTC has about $30bn in AUM, existing shareholders like me are experiencing a destruction of value of around $7.5 billion!!! Why do this?! 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’m writing from Delaware with gratitude for 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. Please take the action necessary to approve a spot Bitcoin ETF. I thank you for your time and your consideration. Sincerely, Justin Henderson