May. 10, 2022
Dear SEC, I’m writing to support the conversion of Grayscale Bitcoin Trust (Symbol: GBTC), currently the world’s largest Bitcoin fund, to the first Spot Bitcoin ETF in the United States. I am an individual investor residing in the state of Texas, USA. As an individual investor, I seek to own BTC and other digital assets through various methods (self custody, regulated exchanges and lending platforms) to diversify risk. Acquiring BTC exposure through an SEC-approved and regulated product such as Grayscale BTC ETF would help further diversify custodial risk. In regards to price manipulation... Where do SEC approved futures-based BTC ETFs derive their price data from? Currently, actual Bitcoin only trades on spot crypto exchanges or through peer-to-peer on-chain transactions. Does it not stand to reason that both the spot and futures-based BTC ETF products would derive price data from these same spot exchanges? Why are futures-based BTC ETFs getting approved, but not an ETF that holds actual Bitcoin? Bitcoin trades 24/7 on crypto exchanges all around the world. I cannot think of a more liquid and transparent financial asset. An SEC-approved, fully audited BTC ETF (that holds actual Bitcoin, not paper contracts) would be a net positive for all US investors. A spot BTC ETF does not seem any different than a Gold ETF. Gold buyers can choose to own the physical asset and self-custody, custody with an 3rd-party intermediary, or own a financial product like an ETF to gain exposure to the underlying asset. This illustrates the fact that the United States is falling behind other countries such as Canada, Brazil and Australia that have already approved spot Bitcoin ETFs. Not to mention that the US is far behind many other countries in terms of digital assets innovation and regulation in general. Careful consideration should be taken as to how the underlying asset is custodied and secured by the GBTC team. Such as requiring multiple keys to authorize a Bitcoin transaction, rather than a single signature from one key. However, I believe these methods have become standard practice in the industry and the process for secure custody of assets have improved dramatically over the years. Please leverage the experience and expertise of incumbent US crypto exchanges and custodians such as Coinbase, Kraken, Gemini, Fidelity, and BitGo for further guidance on how to move forward on this necessary product. Sincerely, Rodrigo Ortega Individual Investor