Apr. 22, 2022
Dear SEC, My name is Evan Hartley. I live in Iowa City, Iowa. I'm writing out of my frustration in the process of gaining approval for the conversion of GBTC into a spot Bitcoin ETF. I feel you are not protecting my interests. In fact, you are hindering them by restricting the type of investments I would like to make in my ROTH IRA, which is that of a spot Bitcoin ETF. 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, shareholders like me are experiencing a destruction of value of around $7.5 billion. I’m writing from Iowa, with gratitude for the opportunity to express my view and with the hope that you will approve this conversion and protect the interest of investors. Sincerely, Evan Hartley