Apr. 25, 2022
Dear SEC, I’m writing to support the conversion of Grayscale Bitcoin Trust (Symbol: GBTC), currently the world’s largest Bitcoin fund, to the first Spot Bitcoin ETF in the United States. I am a "sophisticated " investor, according to SEC guidelines and am fully cognizant of the risks associated with an investment in bitcoin. I have literally spent hundreds of hours researching this asset by reading numerous books and white papers, listening to dozens of Bitcoin podcasts, and discussing the subject matter with many knowledgeable industry leaders. My IRA allocation to GBTC was the most intellectually and risk-aware grounded investment decision that I have ever made. Furthermore, this decision was predicated on the reasonable assumption that, in the not-too-distant future GBTC would convert to an ETF. The SEC's refusal to allow for this conversion has introduced a new and unanticipated risk to my investment and has created the circumstances in which GBTC is now trading over 25% below NAV. This discount represents a significant on-paper loss in my retirement account and hampers my ability to plan for my eventually leaving the workforce. Were the ETF conversion to be allowed this discount would likely narrow immediately, which would align with the investment conclusions at which I very carefully arrived after over two years of deep research. Additionally, I am certain that thousands of other retail investors share my perspective on this and have equally invested a great deal of research time, intellectual energy, and money in this asset. There is no justification for not allowing this conversion. Your actions are not congruent with the mandate to protect investors; they are in fact creating a harmful outcome for thousands of retail GBTC investors. Please consider my thoughts on this matter and allow for the conversion of GBTC to a spot bitcoin ETF. Very best regards, Alan Handler