May. 10, 2022
Dear SEC, I am a Manager of a small Private Equity Fund that provides much needed construction funds for builders in the Portland, Oregon market and I am in favor of approving the Form 19b-4 that NYSE Arca filed with you to convert Grayscale Bitcoin Trust (OTCQX: GBTC) – the world’s largest publicly traded crypto asset fund, with approximately $30 billion in AUM, hundreds of millions in daily trading volume, more than 850,000 investors, holding approximately 3.4% of all Bitcoins outstanding – into a Bitcoin Spot ETF. We want to carry BTC as a long term hedge to de-risk our portfolio. Unfortunately accounting rules make this VERY difficult for us to do as its FASB treatment on the balance sheet is prejudicial. GBTC would make it possible for us to do this and protect our investors and builders. This year, GBTC has traded at an approximately 25% discount to its NAV, which means the price of GBTC is less than the price of its underlying assets, Bitcoin. With approximately $30 billion in AUM, that results in approximately $7.5 billion of trapped value from existing U.S. investors. Thank you for considering my opinion on this matter. With great sinceirty, Richard Sundvall