May. 09, 2022
Dear SEC, I write to you as an experience investor of over three decades and 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. By not approving this conversion, you are not protecting me, the investor – the very person you were appointed to protect. Last October, you approved futures-backed Bitcoin ETFs, but continue to reject applications for spot Bitcoin ETFs. In my opinion, it seems that the SEC has approved the riskier of the two options and has failed to approve the least risky and easier to understand product. In addition, GBTC itself is more risky than an ETF because the shareholders are taking on the risk of Bitcoin as well as the added risk of the trust structure. 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’m writing from Texas, with gratitude for the opportunity to express my view and with the hope that you will approve this conversion and protect the interest of investors. Sincerely, Andrea Hargreaves