May. 17, 2022
To whom it may concern, I write to you today as an American business owner, investor, and Grayscale Bitcoin Investment Trust (GBTC) shareholder. I am in favor of approving the Form 19b-4 NYSE Arca filed with you to convert the Trust into a Bitcoin Spot ETF. GBTC is currently trading at a severe discount to its NAV, harming investors like myself who purchased GBTC shares at or above NAV. Converting GBTC to an ETF would eliminate the discount/premium problem, benefitting investors, while harming no one. Denying Grayscale's ETF conversion would only suppress the value of an already discounted asset, further harming investors, directly contradicting the mission of the SEC. Particularly in view of SEC's approval of several futures-based Bitcoin ETFs, which are unquestionably suboptimal for investors than spot ETFs, it seems abundantly clear that a denial of Grayscale's ETF conversion would be arbitrary and capricious in violation of the Administrative Procedure Act. Allow GBTC to become an ETF. Sincerely, vincent m pugliese