May. 10, 2022
If the SEC really cares about individual investors and investor protection, it should approve the Form 19b-4 that NYSE Arca filed with you to convert Grayscale Bitcoin Trust (OTCQX: GBTC) – the world’s largest publicly traded crypto asset fund, with approximately $30 billion in AUM, hundreds of millions in daily trading volume, more than 850,000 investors, holding approximately 3.4% of all Bitcoins outstanding – into a Bitcoin Spot ETF. With such a large investor, base, it's clear that individual investors are the largest shareholders, and their interest should be held first and foremost in your rulemaking. This year, GBTC has traded at an approximately 25% discount to its NAV, which means the price of GBTC is less than the price of its underlying assets, Bitcoin. With approximately $30 billion in AUM, that results in approximately $7.5 billion of trapped value from existing U.S. investors. This is entirely the fault of SEC's failure to approve this product. You cannot in good faith continue to harm investors by refusing to allow a spot ETF for Bitcoin, when there is already precedent of a futures ETF, which functions on the same principles. -- Edgar