Feb. 28, 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. I understand that one of the concerns is getting an accurate cash price. I’ve been following TradeBlock.com for months now and their methodology of trade-weighting the price of four very large centralized exchanges leads to very accurate estimates of the price one would receive if transacting in the cash market place. In any case, the current discount to NAV of GBTC (and ETHE and GDLC) of 24% currently far dwarfs whatever minor variations there may be amongst the various exchange prices. By allowing the conversion of GBTC (and ETHE and GDLC) to an ETF, you would have a significant and positive impact on the investors who hold these both by collapsing the discount and because the price of the converted ETFs would then much more accurately track the price of the underlying cash on an ongoing basis. Sincerely, Gordon Bennett