Mar. 25, 2022
Dear SEC, Please permit the conversion of Grayscale Bitcoin Trust (GBTC) into a spot ETF. I am aware of Chairman Gensler's concerns that Bitcoin is the "wild west." But remember that the wild west was tamed only by allowing people to own it outright. Likewise, BTC spot ownership is outright ownership; not some futures derivative product which promotes the worst kind of speculation. The world is passing by the US by embracing spot Bitcoin. Look at Fidelity's maneuvers beyond our shores; it is pushing, and succeeding, at allowing non-US Bitcoin investors to buy spot. There has to be a way to quickly allow for a regulatory scheme that adequately protects spot investors -- even if it is disclosures of the type the SEC always embraces. You know what I mean: prominent cautionary warnings on advertisements, offering docs and the like. BTC technology is simply not going to wait for the regulatory wheels to turn at their usual glacial pace. It does not care; tick tock, next block. Bitcoin is here to stay; and with respect, the current SEC stance on spot BTC ETFs actually undermines the SEC's image as the protector of investors. Why? It creates, to the reasonably knowledgeable investor, the appearance of impropriety at the SEC. This is because derivatives ETFs are so great for manipulating markets, including the markets in Bitcoin. So it seems like the SEC is unfairly helping its Wall Street buddies (where SEC people go to work after their stints in DC). All at the expense of some BTC investors who, with proper disclosure, can easily fend for themselves. It is long past time for GBTC to be permitted to meet its destiny: becoming a spot ETF. Please use your ample brains and good hearts to do the right thing. Greg Gross (Securities Lawyer, BTW)