Mar. 03, 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 live in New York State and run a SEC registered investment advisor. My firm was founded in 1981 and for the last forty years, we have always searched for closed-end funds trading at a discount to NAV as a source of alpha. While GBTC is a trust and not a closed-end fund, we believe the only way for the discount to be realized by shareholders is for the SEC to allow for the fund to be converted to a Spot Bitcoin ETF. It is rare for the SEC to be offered “low hanging fruit” that can be easily plucked in order to drive shareholder value. As a result, we urge you to act with alacrity. Sincerely, Chris Mullarkey Managing Member Markston International LLC