Mar. 12, 2022
Dear SEC, I’m writing to express my enthusiastic support for 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. In light of the numerous Spot ETF rejections that have been issued thus far, it occurs to me that the SEC may have painted itself into a corner. How can this one -- put forth by Grayscale -- really be *that* different from those proposed by NYDIG, Global X, Fidelity, VanEck, etc.? But of course, Grayscale is indeed QUITE different, in that it has judiciously (and voluntarily!) reported to the SEC for many years already, and has been protecting investors in the Bitcoin space ever since its inception in 2013. On top of that, its holdings of roughly 642,000 Bitcoin would make it by far the most liquid ETF if the pricing structure were ever to migrate away from an Index-based aggregation. If for some reason the SEC finds itself unable to approve this rule change, I worry greatly about the potential reputational risk to the US financial system. When well-structured investment vehicles designed for everyday investors like myself are held hostage by the SEC, it forces me to look elsewhere for wealth preservation. - Benjamin Burrows