May. 06, 2022
To the SEC: As a GBTC shareholder, I am writing to urge your support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) to an ETF. Failure to approve this conversion would be harmful to investors, which I believe to be the exact opposite of your intended purpose. Your approval of futures-backed Bitcoin ETFs last October was a significant positive step, but it stands in stark (and somewhat baffling) contrast to your continued rejection of applications for spot Bitcoin ETFs, given that both vehicles derive their prices from the same underlying asset, Bitcoin. Investors should be able to choose whether we want direct or futures-based exposure to that asset. As the world’s largest publicly-traded cryptocurrency fund, GBTC holds approximately 3.4% of all Bitcoins outstanding. The fund is held by more than 850,000 investors and has a daily trading volume in the hundreds of millions of dollars. But GBTC has averaged about a 25% discount to NAV this year, i.e., the price of GBTC is less than the price of Bitcoin. With its roughly $30 billion in AUM, GBTC's shareholders are suffering a loss of value of around $7.5 billion. Conversion to an ETF would likely improve this situation substantially. I’m a lifelong Kansas resident attempting, as I believe most Americans are, to secure a better financial future for myself and my family. I appreciate this opportunity to explain my opinions and hope that you will see the wisdom in approving this conversion for the benefit of literally hundreds of thousands of investors. With hope and gratitude, David Seibel