Apr. 22, 2022
Dear SEC, I’m writing to support the conversion of Grayscale Bitcoin Trust (Symbol: GBTC), currently the world’s largest Bitcoin fund, to be the first Spot Bitcoin ETF in the United States. The basis for rejecting a BTC Spot ETF previously was that "the listing exchange had not demonstrated that risks of fraud and market manipulation in the underlying Bitcoin market were sufficiently addressable." There is plenty of that in the physical Gold bullion space, and Gold ETFs are still allowed. The SEC also does not directly regulate Gold bullion, but it does regulate gold, stocks, options, and ETFs. It is part of the SECs mission to protect investors. Allowing a spot BTC ETF Fund would help lower fraud as it would now be managed by a reputable firm that is under the purview of the SEC and can be more regulated. Without a spot ETF, many people are having to self-custody, which has its own issues, or move to other countries who do offer a similar product (Canada), this generally pushes investors away from US regulated markets/protections. It is also in investors best interests, as converting to a spot etf would lower the premium/discount to nav, lower fees, tighten spreads by moving GBTC from OTC to NYSE, and improve tracking. Another rejection by the commission of a spot etf would be continuing to do the US and US investors a disfavor; disadvanging them to the rest of the world. Sincerely, Dingxun (Kevin) Shao