May. 10, 2022
Dear SEC, My name is Didier Lewis, I work in finance and live in South Carolina. I'm writing to you to express that I am strongly 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. 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. To date I have found comments from the SEC completely insufficient and lacking regarding their rejection of previous attempted filings. Furthermore, it is an added disappointment that other countries have already proceeded with a Bitcoin Spot ETF with no issue (notably Canada and Australia). The mission of the SEC is to protect investors; maintain fair, orderly, and efficient markets; and facilitate capital formation. As a Grayscale Bitcoin Trust investor, I can assure you that I do not feel that the SEC is treating me fairly nor am I being protected. To the contrary, the inaction and prolonged delay by the SEC on approving this conversion is making me accrue additional management fees as well as needlessly souring public sentiment for GBTC. Please do the right thing. Thanks, Didier