May 24, 2022
Dear SEC, I am Michael S. Montgomery, a patent attorney from Illinois, 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. I further see no reason that Bitcoin should be treated any differently from any other commodities which are subject to large price fluctuations, such as oil. I really hope you approve this conversion, which will unlock a significant amount of investor value. Right now-- for many reasons-- it is a disservice to keep GBTC as a trust, including significantly worse taxation and higher investor management fees, to say nothing as the significant departure from NAV which would be unlocked. Sincerely, Michael Montgomery, Attorney-at-Law