Apr. 18, 2022
Honorable Chairman Gensler and SEC staff, A U.S. citizen writing in support of GBTC’s conversion to ETF, I am an individual investor nearing retirement age, modestly experienced and sophisticated. My retirement assets require vigilance and protection from a variety of market and $US risks, primarily inflation and devaluation of the $US. I never expected that inaction and delay by the SEC was a portfolio risk I had to mitigate. Under the caption “An Old Dog Learning New Tricks”, I have carefully watched Professor Gensler’s MIT course on blockchain technology and proof of work protocol, >30 hours, admittedly some class sessions multiple times, and read some of the reference materials. In addition, I have done 100s of hours of my own research on this subject. I manage and balance my own portfolio diversified across asset classes with ETFs and mutual funds. I hold Greyscale BTC Trust (GBTC) and am precisely the investor cohort the SEC purports to protect. Astonishingly, the SEC has delayed or failed to approve an ETF for bitcoin (BTC). The SEC’s inaction has significantly impaired the value of my investment in GBTC, now trading about 70% of net asset value. In absurd asymmetry, the SEC has approved BTC futures ETFs fundamentally dependent on BTC spot markets the SEC apparently distrusts. Please correct this and approve GBTC’s conversion to ETF as soon as possible. If you doubt the integrity, vibrancy, and depth of the BTC spot markets, please watch Anthony Pompliano’s 4/6/2022 interview of David Mercer, CEO of LMAX Group, who talks about BTC, macroeconomics, and crypto markets. https://protect2.fireeye.com/v1/url?k=31323334-50bba2bf-3132d782-4544474f5631-dbd3ccd2a48b8104&q=1&e=9b382baf-6670-4594-8e0a-9a6d813f7d54&u=https%3A%2F%2Fyoutu.be%2FBvGbRRXJBBU As you probably know, LMax Digital, an institutional level exchange, is just one of many BTC markets. By my calculation, LMax Digital reports having completed >$74 Billion in trades YTD 4/18/2022, averaging over $20 Billion in trading volume per month! Just one example of a reliable, sophisticated, highly liquid, trusted, and deep BTC spot trading market. Ironically, vast institutional and RIA investment is sidelined while the SEC delays ETF approvals and regulatory clarity. I appreciate your time and attention to this important and urgent matter. Please approve GBTC’s conversion to ETF ASAP. Steve Schuster