Feb. 22, 2022
Dear Members and Staff of the SEC: I am an investor in GBTC, The Greyscale Bitcoin Trust (OTCQX:GBTC), which offers me exposure to Bitcoin. However, the Trust structure does not allow my investment faithfully to track the spot Bitcoin price with the result that the NAV of GBTC can trade at a discount or a premium to the established Coinbase Reference Price of Bitcoin creating more volatility than is observable in the spot price. I strongly support the application by Greyscale to the SEC to convert the GBTC product to a Spot Bitcoin ETF which will better align the investor's objectives with the market value of Bitcoin. Firstly, Greyscale has demonstrated that it is reliable and prudent sponsor of Bitcoin and other crypto currency products. Secondly, it is evident that there is a well established demand for safe Bitcoin products and conversion of GBTC to a spot Bitcoin ETF would offer investors a better and safer choice. Thirdly, since the SEC has already approved an ETF based on Bitcoin futures, it is incomprehensible why it has delayed in approving a spot Bitcoin ETF on the grounds of investor protection especially since the SEC has approved many ETFs including highly leveraged and futures based ETFs that are overtly riskier for investors. Fourthly, in many respects Bitcoin, despite its volatility, is an intrinsically safer product which enjoys considerable investor support, including regulated institutions, because the blockchain technology upon which it is based is transparent and there is a more complete record of transactions and there is no evidence that the Bitcoin blockchain itself has been hacked or is otherwise subject to manipulation. Finally, an SEC approved ETF would set a standard that would strengthen investor protection and confidence and subject the ETF to the detailed rules applied by the SEC. Thank you for your attention to my comments. R O'Toole