Jun. 24, 2022
Dear SEC, I am a retired librarian from the Commonwealth of Virginia, and an individual investor with much of my savings in 403-B, IRA, and HSA accounts - some of which include shares of the Greyscale Bitcoin Trust. I am in favor of approving 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. As I have watched the regulatory discussion regarding a Bitcoin ETF unfold, it has become increasingly difficult for me to understand the logic behind the agency's willingness to approve a Bitcoin futures ETF, and now a short Bitcoin ETF, without approving the more foundational spot ETF. If the agency's stated concern is the stability of the underlying asset and its resistance to manipulation, the approved products seem to me to be counter to that rationale. 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. Sincerely, Braddlee, Ph.D.