Jun. 06, 2022
Dear SEC, I support the conversion of the Grayscale Bitcoin Trust ETF (GBTC) to a Spot Bitcoin ETF. The transparency of the public ledger will provide Grayscale, investors and the authorities with more complete information on the ETFs underlying purchases and sales. Compared to ETFs for other commodities such as gold, the Bitcoin ledger's inherent auditability will help to ensure fairness for investors and hold Grayscale more accountable. The current futures ETF trades at a discount to BTC, and requires higher management fees. This would likely be the case with any BTC futures ETF and is not an artifact of Grayscale's decisions. Converting it to a spot ETF would benefit investors by increasing transparency, eliminating premiums and discounts to BTC price, and reducing management fees. Conversion to a spot ETF aligns with the entirety of the SEC's triple mandate of investor protection, maintenance of orderly markets, and facilitation of capital formation. Thanks, David Banks