May. 06, 2022
Dear SEC - I am a GBTC shareholder residing in Idaho who supports the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) to an ETF. Last October, futures-backed Bitcoin ETFs were approved, but applications for spot Bitcoin ETFs such as GBTC. 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, existing shareholders like me are experiencing a destruction of value of around $7.5 billion. 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. I appreciate the opportunity to express my view to you and with the hope and expectation that you will approve this conversion and protect the interest of investors. Sincerely, Benjamin Goode, CPA