Apr. 22, 2022
Dear SEC, I own significant holdings in Grayscale Bitcoin Trust. Consequently I’m writing to urge approval for the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) — the world’s largest publicly-traded cryptocurrency fund — 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. You surely know that futures investing is one step above gambling, but ETF investing is a vote to support an asset or industry sector for the long term, not the next 30, 60 or 90 days. 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. Since GBTC currently owns about $30 bn in AUM, shareholders like me are experiencing a destruction of value of around $7.5 billion. I’m writing from Durham, North Carolina. I would remind you—your job is to look out for MY best interests. Converting GBTC to a Bitcoin ETF will protect the interest of all current investors, AND open this burgeoning market to everyday investor through a trusted intermediary. Sincerely, Emory M. Bare