May 12, 2022
Dear SEC, I write to you as a GBTC shareholder, in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) to an ETF. By not approving this conversion, you are not protecting me, the investor – the very person you were appointed to protect. In fact, quite the opposite, you are actually taking away the option to safely invest in the Blockchain driven evolution of the financial and Internet worlds to Web3 innovation and making this available only to institutional and HNW investors. This goes against the equal access to opportunity principle of the US government on a new and highly promising asset class. Of course, we need the help of your office to have the ETF regulated per existing standards - but as an individual investor I am ready to take full responsibility and accept the risk of investing in this new asset class based on my own research and understanding. Last October, you approved futures-backed Bitcoin ETFs, but continue to reject applications for spot Bitcoin ETFs. Given are that 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. In fact, the futures based asset is much more complex for me as an individual investor to learn and use. In contrast, an ETF is easy to understand from the perspective of holding the financial equivalent of an amount of BTC in safe custody of the provider with the value equalized to market. Opening this up to competition will also guarantee lower fees than compared to the current GBTC - where my investment is incurring 2% in fees annually. Furthermore, the discount to NAV in GBTC has been around 25%, on average, this year. This means that the price of GBTC is less than the price of Bitcoin, the asset itself. Given that GBTC has about $30bn in AUM, shareholders like me are experiencing a destruction of value of around $7.5 billion - which could otherwise be part of my net worth and be used as collateral if I choose to. I’m writing from California, 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, Ranadeep Ray Fremont, CA 94539