May. 10, 2022
Dear SEC, I write to you as a GBTC shareholder, in strong 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. 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. It doesn't make sense to have multiple Bitcoin futures ETFs in the US and not a Bitcoin spot ETF. Many other nations and countries have already approved Bitcoin spot ETFs all around the world. Why is the US the last to make this adoption and change? The SEC is not protecting investors by not approving a Bitcoin spot ETF. 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. By approving this conversion, you are acting in the best interest of me, the investor. You were appointed to protect me, and now is your chance to fulfill your duty by approving this conversion! Regards, Harold Tan -- Harold Y. Tan