May 24, 2022
To whom it may concern at the Securities and Exchange Commission, 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. The SEC should not hinder US investors' access to Bitcoin and other cryptocurrencies by rejecting applications for spot Bitcoin ETFs. I do not feel protected by these rejections; in fact, just the opposite. Please do not allow other countries to become the leaders in this financial innovation. Last October, you approved futures-backed Bitcoin ETFs, but continue to reject applications for spot Bitcoin ETFs. Given 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. As a result of your continued rejection of applications for spot Bitcoin ETFs, I have felt forced to invest in foreign ETF products, such as the Canadian Purpose Bitcoin ETF (TSE:BTCC.B), in order to meet my investment objectives. 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, existing shareholders like me are experiencing a destruction of value of around $7.5 billion. GBTC is the world’s largest publicly-traded cryptocurrency fund, with hundreds of millions in daily trading volume. It holds approximately 3.4% of all Bitcoins outstanding, and is held by more than 850,000 investors, like me. I’m writing from Pennsylvania, with gratitude for the opportunity to express my view to you and with the hope and expectation that you will approve this conversion and protect the interest of investors. Sincerely, Andrew Cardin