May. 06, 2022
Dear SEC, I’m writing to support the conversion of Grayscale Bitcoin Trust (Symbol: GBTC), currently the world’s largest Bitcoin fund, to the first Spot Bitcoin ETF in the United States. GBTC currently trades at a substantial discount to its NAV given the nature of the vehicle. An ETF structure would serve investors better by allowing them (myself included) and their families to achieve a return that tracks the underlying spot market more accurately. In addition to removing this discount, an ETF structure would dramatically lower fees for GBTC investors. A spot Bitcoin ETF would also give investors a way to invest in Bitcoin through an ETF structure that would directly track the price of Bitcoin; whereas, the current futures-based ETFs expose investors to tracking error relative to Bitcoin’s price, and incur significant and unnecessary costs from rolling the futures every quarter. Investors should be the ones who decide whether to invest in a spot or futures based Bitcoin ETF. By approving only futures based ETFs so far, despite their reference to the same underlying spot market, the SEC has been leaving investors with no choice other than to pay high fees (directly and indirectly), only for them to not achieve their investment objective of diversification through proper tracking of the Bitcoin spot market. Thank you for your thoughtful consideration.