Mar. 01, 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 have been an investor in Bitcoin and its ecosystem of service providers, miners, hardware makers and financial system integrators since 2017. I have been self-managing my investment portfolio for more than 20 years, and in that time I have encountered numerous companies, assets, instruments, technologies, regulatory changes and all the other complexities and uncertainties that come with this endeavor. As an Investor, I accept a degree of uncertainty, irregularity, and risk. In 2017, I felt that the ecosystem was too immature for a spot ETF, and I agreed with your decisions of that era. But the Bitcoin ecosystem has matured very quickly, and my opinion has changed. Today, I hold GBTC in retirement accounts: it was my only option at the time. I also hold large positions of Bitcoin on two US exchanges, both as live assets and as physical Bitcoin in custody. These options are, sadly, inadequate. My preference would be to consolidate all of it to a spot ETF, and Greyscale’s conversion would be the ideal solution. While I could go to an OTC option on a foreign (probably Canadian) exchange, I simply can’t understand why that should be necessary at this late stage. The time has come. We are ready. Sincerely, Michael Palmeter Mike Michael Palmeter MP, VANDUSEN & PALMETER LLC