May 12, 2022
Dear SEC, I am Ben Werkman from Michigan 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. 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. Reducing risk to the investor should identify this inefficiency currently in the market and allow for the correction of it. As a long term investor in Bitcoin, I have witnesses tremendous growth out of the industry particularly over the past 3 years. What has become clear is that Bitcoin offers indiscriminate global utility across the globe. With the rise of nations such as El Salvador and Central African Republic adopting Bitcoin as legal tender, and a host of others allowing Bitcoin the treatment of property, it is becoming time for the US investor to have an ETF which allows spot exposure to this asset class. There is no protection to preventing a spot ETF, particularly while paper trading through futures ETFs continues to be allowed. The approval of the futures ETFs open the investors to the same level of risk as a spot ETF product would allow. Unlike the derivatives being utilized for the other products, a spot ETF is singularly focused. A spot ETF will open investment to a quickly emerging market for corporations without requiring the direct holding of the asset which currently complicates accounting under FASB rules due to the lack of fair value accounting. While this will likely be corrected in the upcoming years with the 7-0 vote of FASB to review the matter as a project, institutions require institutional grade investment vehicles of which a spot ETF would allow for. As investors, we are ready to join the global market in participating in investment in the primary digital property asset, Bitcoin. We request that you review this matter with prudence and we look forward to a standard investment vehicle with direct exposure to the asset it represents. Thank you for your attention and efforts on reviewing these matters. Sincerely, Ben Werkman