Mar. 08, 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 am resident of California (all my life). Currently U.S. investors have limited options to buy Bitcoin: 1. They can buy through an exchange: This comes with risk of losing the connected phone or the exchange having issues. 2. They can self custody: This comes with the risk of losing/forgetting/misplacing one's private keys. It is not for everyone. 3. They can buy GBTC in brokerage or retirement accounts: which currently because of the trust structure, does not track the actual price of Bitcoin, which has created investor losses and pain the past 18 months. Converting GBTC to an ETF will provide a lower cost alternative to investors that more accurately tracks the spot price of BTC. In addition, several other countries have approved spot ETFs, putting the U.S. behind on adoption and hurting U.S. investors that do not have access to foreign markets for a spot ETF. I view this similar to gold and silver, which have ETF's approved for nearly 20 years. Bitcoin can be considered a risky asset: the SEC has approved several 3x leveraged ETF'S and Mutual funds, SPAC's, and allows the average investor to open an online account and take MARGIN or trade OPTIONS (both highly dangerous for new investors). If U.S. investors are given these dangerous investment tools, they should have access to a low cost spot bitcoin ETF. Yes Bitcoin has had wild swings, but it is not uncommon for small, mid, and even large cap stocks to have 80% swings. It is likely much safer for the average investor to be able to buy a bitcoin ETF in a brokerage or retirement account: with built in and established security and safeguards, than to buy on exchanges or self custody. Finally, the argument that bitcoin can be manipulated isn't fair: Stock prices are routinely manipulated with large buy/sale pressure and talking heads, but still trade openly on the market. For these reasons, I strongly believe it is time to approve a spot ETF. Thank you for your consideration. -Matt Apodaca CPA