Jun. 28, 2022
Dear SEC, I am 43 year engineer and father of 3 girls St. Louis, MO and 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. 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. The SECs communicated rationale for denying spot BTC etfs far exceeds the scrutiny you have placed on other spot commodity etf products in the past such as palladium, platinum, gold, silver, and even uranium. Recently, I have heard the SEC frequently discuss protecting investors, particularly retail investors. However, I do not understand how that statement squares with approving a BTC futures etf which exposes retail to effects such as contango and backwardation. I had a coworker the other day mention that he wanted to buy that BTC ETF and I had to explain to him about how future etfs work, the cost to roll a contract, and tracking error. This futures based ETF is not a retail product, and I find it disingenuous to offer this type of product to investors while denying them access to a spot product. Sincerely, Jim Stanec