May. 06, 2022
To whom it may concern, I am writing this letter to express that the Grayscale Bitcoin Trust (GBTC) should be turned into an ETF. The following are my reasons: 1. There are hundreds of thousands of owners of this "security". I know I bought it rather than Bitcoin on Coinbase or another exchange because I could trust the custody at Fidelity where my account is open. I felt comfortable that I was buying a product on a regulated U.S. exchange. In addition, I wanted to put it into my retirement account which is not possible with instruments. 2. Buying an ETF in a fidelity account should be far more desired by the SEC than going out and buying it in an anonymous wallet. 2. The SEC has an explicit mandate of protecting smaller investors. However, the SEC policy is causing this instrument to trade at a discount to the underlying Bitcoin. This discount has continued to widen during the last year. This has caused myself and others to lose capital unnecessarily. 3. Approving a futures-based instrument has only exacerbated this discount. In essence, a futures-based product is no different than an ETF based product so I'm not understanding why they should be treated differently. 4. The regulatory body has stated that it is trying to protect small investors. However, small investors are more informed and in control of their investing finances than ever before. There is copious amounts of research that help investors to make decisions on these products that are no different than the risks in stocks. All instruments have risks with different risk / reward relationships. 5. The SEC has also given the green light to 2x and 3x levered ETF products that I could argue are as volatile if not moreso than a bitcoin ETF. Using an example of the SOXL triple levered Semiconductor ETF. This instrument is down 70% YTD yet there is no discussion about banning these types of instruments. I could go on with more examples as to why it makes sense to allow this product to be converted into an ETF but the ones listed above cover the topic fairly well. I appreciate your consideration of my letter. Dan Sheridan