May. 10, 2022
To the SEC, Please allow GBTC to be converted to an ETF. ETF's are by far the most efficient investment wrapper available today for most asset classes, including spot bitcoin. The ETF's creation/redemption process will protect retail investors because it provides market making/arbitrage desks profit incentive to keep the shares tracking in line with the underlying asset, regardless of the underlying asset's performance. Retail and institutional investors in GBTC (under its current closed end fund structure) are getting screwed as evidenced by the 20%+ discounts that the shares are trading at relative to the funds NAV. The SEC should choose to protect all current and future GBTC investors by allowing it to immediately convert to an Exchange Traded Fund. Please feel free to contact me if you have any questions or would like to discuss further. Best regards, Bryan Halpert Co-Founder