May. 31, 2022
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Dear SEC, I'm California resident nearing retirement 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. I viewed Bitcoin as a small portion of my retirement funds as a source of inflation protection and diversification. This year, GBTC has traded at an increasingly large 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 am now holding shares in GBTC which are under water solely because of this huge discount to NAV which has developed recently. It is my understanding that an ETF structure would allow market traders to correct this anomaly so that investors could enter and exit GBTC without worrying about the esoteric, though in this case crucially important, NAV premium or discount. The current structure allows anyone to invest, the unknowing perhaps investing at points of high premium to NAV and then needing to sell at a large discount to NAV. The current structure is bad for investors, old and new. Sincerely, Phillip Duncan