May 22, 2022
Dear SEC, I’m writing to support the conversion of Grayscale Bitcoin Trust (Symbol: GBTC), currently the world’s largest Bitcoin fund, to the first Spot Bitcoin ETF in the United States. I've been observing that the spot Bitcoin price (USD/BTC) is much less volatile compared to the currently available proxies such as GBTC and MSTR. Those proxies fluctuate 10% or more a day, even when the spot Bitcoin price moved less than 5% on that day. They are already traded at a deep discount to their NAV and thus inferior alternatives to a true spot Bitcoin exposure. Why would we allow such inferior proxies available to investors, but not a spot Bitcoin ETF? GBTC has been a trusted custodian of a large body of Bitcoin. Converting GBTC to an ETF will protect investors from unnecessary volatility and price discount/premium and reduce the friction of OTC transactions. It is clear now that Bitcoin is a commodity unlike other cryptocurrencies and not a security. All American exchanges are compliant to relevant regulations, already. I believe it is time to allow a Bitcoin ETF. Sincerely, Duckki Oe