Feb. 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. Below list the current situation and why GBTC should be converted to a spot ETF. 1) The SEC has already approved a future's based Bitcoin ETF (ex. BITO). The entire purpose of the future's ETF is to roughly match the price of bitcoin. It may not be exact but in essence if BTC were to jump 25%, BITO would increase in value similarly. If BTC were to drop 40%, BITO would follow suit roughly (maybe even worse). 2) A future's based product doesn't do a whole lot to mitigate any fraud or manipulation with the core asset it's 'tracking'. In fact it's likely worse as there will be a premium (positive/negative) based on the fluctuation of BTC. 3) A spot ETF would theoretically be safer as it would remove all discounts or premiums to the asset it tracks. This will reduce the harm and also reduce manipulation. 4) Approving the GBTC proposal will allow for a large inflow of dollars (billions) into the BTC market cap. This will help reduce volatility since at that point Grayscale will be one of the largest custodians of BTC. Grayscale would be a SEC regulated company and naturally not be able to engage in any illegal practices with the assets. 5) Americans are already purchasing BTC via Coindesk, Binance, Kraken etc. Providing a SEC regulated option would be the primary choice for many investors (retail + institutions). 6) I understand a rule change would need to occur, but at this point money is finding a way to get into crypto regardless. It would be best for the SEC to be forward thinking here and recognize that a spot BTC ETF will have to come into existence at some point on the US markets. 7) Grayscale's GBTC is already very large and they are asking for a simple conversion from a trust to spot ETF. They have a proven track record of financial integrity. They should lead the pack. In closing I highly recommend the SEC pay close attention to these points. The bottom line is that millions of americans are looking for a way to purchase crypto currency, if they have not already. Offering a SEC regulated option on the public markets provides superior protection for investors. Sincerely, Jerry Koberlein