May. 06, 2022
Dear SEC, I write to you as a GBTC shareholder, in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) to an ETF. Approval of this conversion will assist small investors like myself, and represents the clearest way for you to uphold your mission, to protect such investors. 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. It is also my personal opinion that supporting a futures based platform over a spot price platform encourages volatility in the market, and privileges large investors with extra capital and knowledge. GBTC is the world’s largest publicly-traded cryptocurrency fund, with hundreds of millions in daily trading volume. It holds approximately 3.4% of all Bitcoins outstanding, and is held by more than 850,000 investors, like me. I’m writing from the state of Utah with appreciation for the opportunity to express my view to you. I hope that you will approve this conversion and protect the interest of investors. Sincerely, Kyle Bulthuis