November 4, 2021
It is unquestionably in the best interest of retail investors for the SEC to approve Grayscale's petition to convert GBTC into an ETF. The ETF structure will substantially reduce the discount or premium to NAV that the trust has traded at historically (bad for investors given that the fund takes its 2% fee on the NAV and not the market price of the shares), and will provide inexpensive access to secure third-party Bitcoin custody for retail investors who are currently unable to pursue that avenue for investment.
There is, in my opinion, no case to be made that an ETF based on the underlying asset (especially one that provides proof of reserves as a spot-based ETF would be likely to do) is any less safe for investors than one based on derivatives of that asset, especially when said derivatives sometimes trade at a significant premium. This is a cost passed along to retail investors that would not be an issue with a physically-backed ETF.
Please allow Grayscale to convert, even if for no other reason than that many of the current GBTC investors are retail customers who are unwilling to exit their investment at a discount to NAV. Simply allowing the fund to convert should alleviate this imbalance between supply and demand and prevent retail investors from paying a higher fee than they originally agreed to when they purchased the fund.