May. 06, 2022
Dear SEC, I write to you as a GBTC shareholder, in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) — the world’s largest publicly-traded cryptocurrency fund — to an ETF. I strongly encourage that the SEC protect me as an investor. Last October, the SEC approved futures-backed Bitcoin ETFs, but continue to reject applications for spot Bitcoin ETFs. The unintended consequences of not approving a spot ETF that can be regulated is to push the average consumer, like myself, to take unprecedented risks on unregulated exchanges and unregistered products to gain exposure to this emerging asset class. 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. Furthermore, the discount to NAV in GBTC has been around 25%, on average, this year. This means that the price of GBTC is less than the price of Bitcoin, the asset itself. Given that GBTC has about $30bn in AUM, shareholders like me are experiencing a destruction of value of around $7.5 billion. I am in full support of the SEC’s consumer protection responsibility by providing fair and equitable access to Bitcoin and GBTC as an ETF investment. I’m writing from Hawaii, with Aloha for the opportunity to express my view and with the hope that you will approve this conversion and protect the interest of investors. Mahalo! Earle Ifuku