May 12, 2022
Dear SEC, I write to you as a GBTC shareholder, in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) — the world’s largest publicly-traded cryptocurrency fund — to an ETF. GBTC is currently trading at a substantial discount to its NAV, averaging about 25%. This means that the price of GBTC is less than the price of Bitcoin, the asset itself. Converting it to a spot ETF would result in the shares trading at the Fair Market Value commensurate with the price of the underlying Bitcoin. This would clearly benefit investors like me who will see the value of our investment go up. We are being hurt due to the spot ETF conversion not being approved as the premium to NAV has turned into a steep discount over the past year. Given that GBTC has about $30bn in AUM, shareholders like me are experiencing a destruction of value of around $7.5 billion. Also, last October, you approved futures-backed Bitcoin ETFs. Since investors use both vehicles to gain exposure to the same underlying asset, Bitcoin—from which both vehicles derive their prices—we, as investors, should be able to choose if we’d like direct or futures-based exposure to that asset. I’m writing from Austin, Texas, with gratitude for the opportunity to express my view and with the hope that you will approve this conversion and protect the interest of investors. Sincerely, Abhishek Tondon