May. 10, 2022
Dear SEC, As a retiree and a GBTC shareholder, I support the conversion of Grayscale Bitcoin Trust (OTCQX: GBTC), the world’s largest publicly-traded cryptocurrency fund, to a spot Bitcoin ETF. By not approving this conversion, you are not protecting me, the investor, rather you are subjecting me to GBTC prices that trade at a discount or premium to the fund NAV. Converting GBTC to an ETF will result in a cryptocurrency fund based upon NAV of the assets under management, thus more accurately reflect the current price of Bitcoin. Grayscale is also committed to reducing its relatively high management fee if the conversion is approved by the SEC. 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 investors should be able to choose if we’d like direct or futures-based exposure to that asset. The current discount to NAV in GBTC has been about 25%. 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 Michigan, and thank you for the opportunity to express my view and with the hope that you will approve this conversion and protect the interest of investors. Sincerely, Joe Freiman