Apr. 22, 2022
Dear SEC, Thank you for taking comments about the proposed conversion of GBTC to a spot price based ETF. I am not a particularly savvy investor so maybe hearing my bitcoin story will be useful to you. Many years ago, I had a long distance phone company that would only charge me for the long distance calls I made (unlike a lot of the most popular carriers that had instituted a monthly access charge whether or not you made any long distance calls). This company used to give out "smile points" (kind of like digital green stamps if you are old enough to remember what they were). At some point, it was mentioned that one could trade these "smile points" for a new thing called bitcoin. My take on it - why bother trading one practically worthless thing for another practically worthless thing? Eventually the phone carrier lost its ability to provide phone service in California (which is where I live) so I decided I might as well try to "monetize" my (not very many) "smile points" before closing my account with the phone company. By then, trading "smile points" for bitcoin had become more difficult, mainly because at that time bitcoin had started to gain its footing and have (at least a little) real value. I found one entity that was still (possibly) trading bitcoin for smile points but trying to get to them was like something from Alice in Never Never Land. I had to find some way to get to a part of the Web that was very foreign to me. I think I also had to set up a folder or wallet that could contain the bitcoin, then I had to try to contact the entity that (might!!) still be offering to convert the "smile points" (probably less than $5.00 worth) to bitcoin. I remember offering my points and giving my wallet address of something like 100 letters and numbers. To this day I have no idea whether the transaction went through. I figured this bitcoin stuff was not for me. Fast forward 10 or 15 years, I had set up a small traditional IRA with a NYC firm and my broker had recommended purchasing a Mutual fund (because the head of this fund was a successful and brilliant guy). The Fund got burned in one of the big downturns, but came roaring back to about 4 times its original value (currently). This fund notified us about 10 years ago that they planned to invest up to 10% of their funds in bitcoin. When bitcoin went to the moon, this Mutual fund did VERY well. There was no way I was going to invest in Bitcoin directly because I'm terrible at remembering passwords and if I forgot my bitcoin wallet password I'd just be flushing my funds away. So I checked the Mutual fund's list of largest investments to see how they had invested in Bitcoin. Turns out they had invested through GBTC. As a small investor I couldn't invest with them in exactly the same way, but I could invest with them. I put maybe 3 days salary into the fund (in a Standard IRA account) to use as "insurance" should the US dollar keep inflating itself at a super rapid pace. I think that was prudent. Time will tell whether or not that little bit of bitcoin related "insurance" pays off. On the downside, I lose a couple days pay. On the upside - who knows. One never wants to need to collect on insurance but having at least a small amount of it can be wise. In short GBTC offers a valuable service. Letting them convert to a spot ETF would make them more efficient (and a bit less costly in terms of the transactions they would need to make to keep the fund operating). I'm no genius, but for a person like me, allowing this GBTC conversion would be helpful. Thank you for your time. Sincerely, Joseph Valent