May. 06, 2022
Dear SEC, I am a GBTC shareholder who supports of the conversion of the Grayscale Bitcoin Trust (OTCQX: GBTC) to an ETF. By not approving this conversion, you are not acting in my best interest nor protecting me, the investor – the very person you were appointed to protect. In fact the prior approvals of non-spot ETFs that banks can manipulate seems like a poor move on your part and is disrespectful of intelligent Americans. I’m concerned you have forgotten that competition and freedom are what built and sustain America. With that in mind, why do you 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 me are experiencing a decrease in value of around $7.5 billion. I’ve moved to and live in Texas, possibly the last state that believes America is still the land of the free. Thank you for the opportunity to express my view. I hope that you will approve this conversion and protect the interest of Americans and investors. Kind regards, Falan Memmott, US citizen