May. 18, 2022
I think the SEC should allow the conversion of the Grayscale Bitcoin Trust (GBTC) to a spot Bitcoin ETF. Bitcoin is a viable investment concept and the fact that the fund is allowed to exist in its current structure shows that the SEC doesn't have a problem with the concept. It is not consistent with fiduciary principles to force the participation only in a futures form that requires the highly inefficient roll losses to the holders of the BITO ETF. As a CFA charterholder (#5520) I am fully aware of risks and benefits of all investment concepts and vehicles. I would own BTC directly, but as a retiree I don't have the interest to take possession in the required way and would greatly prefer to hire a manager that will give me the exposure and also the custodial function that is difficult. GBTC gives me that and should be allowed to correctly reflect the economic value of the holdings by being a true spot holding of the asset. Thank you for considering. Tom __________________________________________________ Thomas H. Weaver, CFA