May. 10, 2022
Dear SEC, I write to you in support of the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC) to an ETF. 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 should be able to choose if we’d like direct or futures-based exposure to that asset. 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’m writing from New York, with gratitude for 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 J Dame