Feb. 23, 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. My concern is that, by not approving the ETF, the SEC is doing the following: Forcing institutional investors to look outside the US for exposure to this asset. By forcing institutional investors outside the US, this creates a discount in the value of the Trust shares. This discount then disproportionately hurts retail investors holding Trust shares who do not have the access to international markets. The underlying asset is recognized as digital property and not a security. This is fundamentally different than many other crypto currencies which meet the definition of a security. An ETF following the prices of this asset is then no different than an ETF following the price of precious metals. The CMT currently trades futures for Bitcoin and the SEC has approved Futures based ETFs. How can the CMT recognize the asset and allow futures contract trading, and an ETF based on futures contracts be allowed by the same governing body, but an ETF based on the spot price of the underlying asset is too risky for investors. This does not make sense. It is playing favorites to institutional investors capable of trading and understanding futures contracts. The SEC is not fostering an environment for innovation and growth. Sincerely, Matt Elkins