May. 10, 2022
I am writing you to show my full support for the conversion of Grayscale Bitcoin Trust (GBTC) to a spot based ETF. I don’t believe there is a materially difference in risks that a spot eft would have that a future based ETF doesn’t have. The bitcoin market has matured a substantial amount, is of adequate size, and also is clearly not a security based on the Howley test unlike most other crypto. If a future based ETF can be approved based on both the 33 and 40 Acts, it is appropriate to approve GBTC especially since it is already established. The SEC would be doing the public a disservice in not approving it since GBTC price is currently not well correlated with the underlying asset. This poses much more risk than the ETF. Please approve the GBTC conversion. Bryan G. Kelley, P.E. Senior Traffic Engineer Simmons & White, Inc.