Apr. 22, 2022
Dear SEC, I write to you as a GBTC shareholder, in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) to an ETF. By not approving this conversion, you are not protecting me, the investor – the very person you were appointed to protect. Last October, you approved futures-backed Bitcoin ETFs, but continue to reject applications for spot Bitcoin ETFs. Given that investors use both vehicles to gain exposure to the same underlying asset, Bitcoin—from which both vehicles derive their prices—we, as investors, should be able to choose if we’d like direct or futures-based exposure to that asset. Furthermore, the discount to NAV in GBTC has been around 25%, on average, this year. This means that the price of GBTC is less than the price of Bitcoin, the asset itself. Given that GBTC has about $30bn in AUM, existing shareholders like me are experiencing a destruction of value of around $7.5 billion. GBTC is the world’s largest publicly-traded cryptocurrency fund, with hundreds of millions in daily trading volume. It holds approximately 3.4% of all Bitcoins outstanding, and is held by more than 850,000 investors, like me. I’m writing from New York with gratitude for the opportunity to express my view to you and with the hope and expectation that you will approve this conversion and protect the interest of investors. I also think it's ridiculous that we live in a digital age and we are using laws from a 1930s. The United States is going to get left behind if regulatory clarity is not done in a timely manner. Bitcoin is inevitable, so delaying a spot ETF is doing nobody any good. The United States has an opportunity to be a leader in the Bitcoin and crypto industry and we are blowing it. The state of New York is leading the way and it's oppression to crypto. It's ridiculous that people can play the lottery and go to a casino, but I can't earn yield on my crypto on platforms like Celsius and blockfi. We also can't have access to various token/coins on certain exchanges because of the oppressive regulations. But we can buy garbage penny stocks on the OTC market. Let people choose what they want to do with their money. Sincerely, Richard Collamore