May. 16, 2022
To SEC, I am requesting the SEC to approve as soon as possible the conversion of GBTC to an ETF. There are numerous reasons for doing so. ETFs have already been approved and established in Canada (three ETFs) and Brazil (one ETF), two more ETFs are expected to be approved this month in Australia, and SEC previously approved a futures ETF. There are also so many advantages with this conversion for retail investors which include: easier trading and holding the shares in existing accounts at a brokerage compared to the more difficult chore of opening additional accounts at a crypto exchange, transferring funds from the existing brokerage account to a crypto exchange, buying the BTCs, buying hard wallets, setting up the hard wallets, making transfers for each transaction from the exchange to the hard wallet, then when selling having to go through the same tedious process in reverse. Each of these steps also present risks to the individual investor such as from fraudulent organizations and hackers, loss of BTCs left in the account at the crypto exchange if it goes bankrupt or hacked, and the potential for losing access to the hard wallet (e.g., forgetting password or seed words) resulting in the total loss of the BTCs. All of these steps also make it time consuming and difficult for retail investors. Also, for IRA accounts, which many retail investors have and prefer to buy and/or trade BTCs, the difficulties are even worse to identify a firm that handles IRA accounts, verifying its legitimacy, opening the additional account, transferring the IRA funds from an existing brokerage account, paying higher fees for such IRA accounts, and monitoring the additional accounts. While some of the above difficulties are improved by buying GBTC rather than the actual BTC, there are added risks to investors with GBTC since the price of GBTC does not directly reflect the price of BTC, and for a long time has traded at a significant discount to the spot BTC. My understanding is that the mission of the SEC is to (1) protect investors; (2) maintain fair, orderly, and efficient markets; and (3) facilitate capital formation. It is clear that currently, by not approving the GBTC conversion to an ETF, investors are not protected (see risks described above) and having to buy BTC directly the BTC market is not often fair, orderly, and efficient. Therefore please approve the conversion of GBTC to an ETF quickly. Thanks, J. Braverman