May. 06, 2022
Dear SEC, I write to you as a GBTC shareholder in Texas in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) into a spot based ETF. 1. The investment is and will continue to trade at a massive discount to fair value, that hurts me as a retail client. 2. Vanguard just restricted trading of OTC products, so now I can’t buy more until GBTC is made an ETF. 3. GBTC is the world’s largest publicly-traded cryptocurrency fund based on the largest cryptocurrency - the latter valued by the world at around $700-800 billion right now. The market is too large to game at this point, even more so if a $30 billion spot ETF were available that was not subject to roll and other fees and expenses that accrue to futures based ETF products like those already approved by the SEC. 4. By not approving this conversion, you are relegating me to paying 2% Mgmt fees whereas a spot-based ETF approval would require a lower fee based on mrkt forces as new providers would build a cheaper way to get the same exposure. 5. the SEC’s recent approval of a futures based BTC product under the 1933 Act shows investors can be protected under the same law that a spot BTC ETF would find regulation. 6. The Palladium mrkt is cornered by a single Russian oligarch - but a spot ETF of that metal was approved by the SEC. How is the mrkt for palladium inherently less risky than BTC then? 7. Other countries have signed off on a spot BTC ETF too, don’t let US investors get left holding the bag for Canada/UK/etc. Sincerely, -Andrew Ingram