On the Grayscale GBTC to ETF spam campaign

Version 2022-06-14

Executive summary

In late 2021, Grayscale asked the US Securities and Exchange Commission (SEC) to authorize the conversion of their GBTC fund, which can be traded only through brokers, to an Exchange Traded Fund (ETF), which would be traded on the New York Stock Exchange by anyone, and included in tax-deferred investment retirement plans (401k, Roth). Then they asked the ~850'000 GBTC share holders to spam the SEC with letters asking for the conversion to be approved.

As of 2022-06-14, the SEC posted about 7681 such letters. I skimmed through them and noted down the letters against the conversion, as well as many others which I found notable for one reason or another. See below.

Index

Grayscale, GBTC, and the ETF

Grayscale is a financial company that created and manages the Grayscale Bitcoin Trust (GBTC), an investment fund whose portfolio consists entirely of a practically static hoard of bitcoins (BTC).

Ordinary GBTC investors can trade their shares with other investors, with some restrictions; but cannot get them redeemed by Grayscale, either in dollars or in bitcoins. Grayscale also takes some of the bitcoins as management and storage fees.

GBTC shares are not traded on stock exchanges like NYSE or NASDAQ, but through a network of securities brokers and dealers. Its share price is implicitly defined by bids and offers of various dealers, which are reported on the OTCQX online service. Unlike those open marketplaces, OTCQX does not handle money or execute trades by matching bids and orders itself. Instead, the brokers listed there trade the shares directly among themselves.

Because of those restrictions and fees, the market price of a GBTC share has for some time been about 25% lower than the Nominal Asset Value (NAV), the spot market price of the BTC in Grayscale's custody that nominally corresponds to that share. As of 2022-06-10, each GBTC share is supposed to represent 0.00092318 BTC, giving it a NAV of 27.69 26.77 USD; whereas its market price is 19.41 USD, a 27.5% discount.

In November 2021, Grayscale requested from the SEC (through NYSE Arca) the conversion of the GBTC fund to an Exchange Traded Fund (ETF). (The filing was amended by NYSE on 2022-04-22.) As such, the fund shares could be traded in a real securities exchange (specifically, NYSE Arca) in the same way as other ETFs and stocks of major publicly owned companies. That should keep the price of the ETF shares close to the spot price of the underlying bitcoins in cryptocurrency exchanges.

In theory, investment in GBTC is restricted to "accredited investors" (those who, among other conditions, own at least 1'000'000 USD of assets) and cannot be used for retirement savings (IRA and 401k). These restrictions are quite appropriate, since the complexity of bitcoin makes its risks and flaws very difficult to see, even by investors with some knowledge of computers or finance. Unfortunately, some brokers and brokerage firms, like Fidelity, have found ways to get around that limitation. Grayscale claims to have more than 850'000 investors, and many of them seem to be middle-class workers or retirees who are already investing their 401k retirement savings into GBTC. This abuse prompted the US Department of Labor had to issue warning against this practice.

The Grayscale spam campaign

Grayscale encouraged the current GBTC investors to write to the SEC expressing support of the conversion, e. g. through this 2022-02-22 tweet and even provided a letter template with slots where the sender should fill their name and place of residence. As a result, the SEC public comments space was overwhelmed with a torrent of "spam" letters (more than 7000 as of 2022-05-29). Judging from the distribution of these letters over time, it seems that at least four such requests were sent to all investors (on 2022-02-22, 2022-04-22, 2022-05-06, and 2022-05-10), with different comment templates.

plot of letters received by date

Grayscale's motivation for the request is clear. Since Bitcoin is not a productive asset, its price will collapse without a continuous inflow of new investment. By converting their fund to an ETF they hope to attract many more investors -- especially the savings of millions of Americans that today find it difficult to invest in GBTC.

Many of the letters imply, or explicitly say, that the SEC and/or Chairman Gary Gensler are corrupt, incompetent, or lazy for not allowing a spot ETF while allowing a futures ETF, and even blame them for the GBTC discount. One wonders how much of this view was created by Grayscale, perhaps in the Template letters themselves. However, some of these insults must also be the result of SEC Commissioner Hester Pierce (known to believers as as "Crypto Mom") publicly criticizing her fellow members for not bending the SEC mission and rules to accommodate cryptos and crypto companies.

(By the way, the Greyscale tweet of 2022-02-22 and the template that they sent to GBTC investors on 2022-04-22 contained claims of advantages that the ETF conversion would bring them. Wouldn't these messages be violations of the SEC rules against advertising a security before it gets approved?)

Misconceptions

Most authors of the letters -- mostly current or prospective GBTC investors -- seem to have some big misunderstandings about the mission of the SEC, particularly what "protect investors" means. Some also may be unaware of consequences of the conversion for their investments. Grayscale naturally did not care to dispel those misconceptions; on the contrary, incorporated them in their letter template.

"Protect investors" does not mean "make my investment more profitable"

The Grayscale model letter includes this sentence, copied by thousands of the letters: "By not approving this conversion, you are not protecting me, the investor – the very person you were appointed to protect." The model letter then explains how the current formulation of the GBTC fund harms its investors because of the significant difference between GBTC share price and the price of the underlying bitcoins.

That line exposes a deep misconception about the SEC's mission. If your investment sours and you lose money, or did not profit as much as you think you should, that is not the SEC's problem. It is your problem, that you should take up with the issuers -- or sell the thing and invest the money in some. In particular, the SEC has no obligation, legal or moral, to help reduce the losses (or increase the profits) of those who decided to invest in GBTC.

The discount between GBTC's NAV and its market price is a consequence of its "qualities", such as the 2% yearly maintenance fee (that will reduce the amount of BTC that each share stands for), the lack of any revenue-generating activity that could go to the investors, other than the hypothetical rise in the BTC market price; and the lack of a redemption of withdrawal process, by which Grayscale would take back its shares and deliver the corresponding BTC or their equivalent in USD. GBTC shares were once traded at a premium, probably because holding and trading its shares was perceived to be safer than dealing with the BTC directly. However, the premium turned into a large discount as better funds became available in other countries, and investors became more aware of the "qualities" above.

So GBTC trades at a discount to its NAV because investors now realized that it is a bad investment. But it is not the SEC's obligation to make bad investments more attractive, so that more investors are lured to them.

If protecting and improving the market price of investments was part of the SEC's mission, they would have to endorse pump-and-dump penny stock scams and ponzi schemes, instead of shutting them down; and praise the scammers who create them, instead of sending them to jail. It just does not make sense.

"Protect investors" does not mean "let me invest in whatever I want"

Many of the letters received by the SEC have words to the effect of "a Spot Bitcoin ETF would allow people like me to invest into the world's most popular cryptocurrency"

The SEC has no obligation, legal or moral, to let a security be freely issued and traded just because millions of people want to invest in it. Quite the opposite.

The SEC was created because the crash or 1929 and the Great Depression showed how easy it is for scammers to sell fraudulent or grossly misrepresented securities, even to investors who believe that they "understand the risks". Thus the SEC's mission is to block selling and trading of such securities to the general public, and to make sure that those which are allowed are correctly described, including all the risks. Moreover, the more appealing an investment is to the general public, the more rigorous the SEC must be in this task.

This story has been repeated in other fields. The Thalidomide disaster showed that it was foolish to let pharmaceutical industries freely market and sell medical drugs, and spurred the creation of government agencies like the US FDA with authority to block drugs irrespective of their popularity. The deaths attributed to the Great London Smog of 1952 and the smogs of Los Angeles and New York led to strict environmental protection laws and agencies like the US EPA. The 1919 Great Molasses Flood of Boston started the present laws that require filing of structural calculations, signed by qualified engineers, before any building project is allowed to start. And so on.

Thus, the thousands of letter authors who demand the ability to invest their retirement savings in a bitcoin ETF, even though they clearly cannot understand the technical and financial flaws of BTC, are in fact a strong argument against the conversion. "The NEMA must increase the size of holes of standard power outlets because there are 15 million toddlers in the US who just want to stick their fingers into them."

In fact, the SEC authorized GBTC only for OTC (broker) trading, and only to "accredited investors" precisely to protect the millions of investors who, unable to understand the nature of BTC and GBTC, would otherwise be lured by the hype of crypto promoters to invest into that fund the savings that they could not afford to lose. That is an example of what "protect investors" means.

Manipulation in existing markets is not an excuse

The SEC has justified their denial of previous Bitcoin ETF proposals with concerns that the the bitcoin market price could be easily manipulated. Several letters reject that justification by pointing out that such manipulation already happens for many securities that the SEC has approved.

However, price manipulation is a very bad thing, no matter which securities it affects. The SEC cannot completely prevent it from happening in securities that it already approved, even though it devotes considerable resources to investigate potential instances and prosecute the agents responsible. Thus it makes no sense to approve a proposed security that is based on an asset whose price is notoriously affected by manipulation but (in the current SEC view) outside their regulatory reach.

Cryptos and all their derivatives are rotten investments

As a payment system for legal commerce, bitcoin is a utter failure, for many incurable technical and economic reasons that have no fix in sight. These include its inherently limited capacity (insufficient to support 5 million users doing one payment per week), extremely volatile value (that can rise or drop by more than 10% in minutes), its sluggishness (minimum 10 minutes for first tentative confirmation, sometimes hours or days), its high operating cost (currently about 25 million USD/day, more than $50 for each transaction, paid by investors rather than users), its insecurity (there is no way to reverse or remedy mistakes, by thefts, or payments to fraudulent merchants), and many more. The Lightning Network, which has been touted for years as a solution for some of these problems, has in fact even bigger problems that will prevent it from serving even the couple millions that Bitcoin itself can handle.

Being a failure as a payment system also makes it a failure for the other uses that have been claimed for it, including "large settlement payments", "reserve currency of the world", and "store of value". As for the latter, in particular, there is no "natural floor price" for bitcoin that is anywhere above zero. (Whereas gold, for example, has a floor price of at least a few hundred USD/oz because of its consumption in jewelry, decoration, and industry.) In fact, this general economic failure is shared by all other cryptocurrencies, even those that are somewhat better that BTC in one or two aspects.

Adoption of bitcoin as a currency of trade is still negligible, in spite of almost a decade of intense marketing efforts by its promoters. Bitcoin has only two significant uses: a tool for illegal payments, and the vehicle for the biggest ponzi-like scam in history.

Illicit uses of bitcoin include ransomware (which was virtually unknown before it adopted bitcoin and is today the biggest and fastest-growing form of cybercrime, causing many billions of USD of damage each year), drugs-by-mail (see Silk Road and all dark markets that followed, responsible for thousands of deaths by drugs like fentanyl-laced heroin), child porn and sex trafficking (see Jeff Epstein, Joel Greenberg, George Nader), tax evasion, bribery, fraudulent sales and investments, and more. These users put up with the flaws above because bitcoin are the only digital payment method that does not respect KYC/AML laws.

Both GBTC and the proposed BTC ("raw" plus ETF) have entities that take out money from the investors. For GBTC it is Grayscale, that skims the BTC in its hoard as maintenance and management fees. For the proposed market, in addition to some residual Grayscale fees, there will be the miners, who take the equivalent of ~900 BTC daily from investors, as they sell their reward coins to them. Therefore, both markets have the same negative sum financial structure of a Ponzi scheme.

If bitcoin is a system whose contribution to humanity is very negative, it makes no sense to allow investment into it, no matter how many people want to do so. And if bitcoin is a rotten investment, any derivatives -- such as bitcoin futures, funds, exchanges, and the like -- cannot be anything other than rotten too.

Bad performance of other assets is not an excuse

Several letters use the argument that other stocks in the authors' portfolios have lost more value than Bitcoin did, and "therefore" there is no reason to block a Bitcoin ETF while allowing those stocks be freely traded and included in retirement accounts.

But that argument is not valid, because the SEC could not tell in advance that those stocks would fail. If it did, if would not approve their listing, per its mission. Whereas it can tell that the price of Bitcoin (or any crypto) is a purely random variable, sustained only by the expectations of traders and investors who do not really understand it, and totally susceptible to manipulation by large players such as "whales", unregulated exchanges, and unbacked stablecoins -- manipulation that will be directed at enriching the manipulators, necessarily at the expense of general investors.

A Futures ETF is not an excuse for a Spot ETF

One of the main arguments made by Grayscale and their lawyers, which was included in their template comment and reproduced in thousands of comments, is that the SEC has already approved a Bitcoin Futures ETF, thus they should not object to the much simpler and more capitalized Spot ETF. The lawyers cite the Administrative Procedure Act (APA) which requires consistency in the decisions of regulating agencies.

However, the two funds have completely different nature. The Bitcoin futures ETF BITO has a source of income that could in theory pay back all its investors with profit: namely the trading of the BTC futures contracts. It is true that the BITO profits ultimately come from losses of the investors in BTC, but at least it is not from the BITO investors themselves.

In contrast, both the GBTC fund and the proposed Bitcoin Spot ETF will have no such source of revenue. While the coins reside in the virtual vaults of those funds, they produce absolutely no revenue -- not even by being used as currency of commerce or illegal payments, not even by being lent for interest.

As long as there is no redemption of GBTC shares, any profit of a GBTC investor can come from only one place: other GBTC investors. The same is true of the proposed ETF, except that, since the hoard will be regularly adjusted by buying or selling BTC on the open marked, the universe of investors is not just the ETF investors but includes also all investors in raw BTC. In other words, the profit of someone who invest in BTC, either "in the raw" or through the proposed ETF, can come from only one source: the money provided by another similar investor.

Moreover, both GBTC and the proposed ETF will have their fate tied to that of Bitcoin: if the price of bitcoin goes to zero (as it must eventually, because of its negative-sum ponzi character), the same will happen to the shares of both funds, and their investors will lose money. Whereas the success of BITO depends on the skill luck of its traders in predicting the BTC price months in advance. Since they can short it (bet on it going down), it is possible that all BITO investors will exit with a profit, even if the price of bitcoin goes straight down to zero from now on. (And, conversely, it is quite possible that BITO investors will lose all their money even if the BTC price only keeps increasing.)

As for the risk of market manipulation, for BITO the main risk presumably is that the fund traders could manipulate the BTC market price to match their futures contracts; which would benefit BITO investors. Whereas the risk for GBTC and the spot ETF is that Greyscale or other traders will manipulate the BTC price to benefit themselves at the expense of the GBTC/ETF investors.

In summary, the approval of BITO is not an argument for approval of the GBTC ETF fund, because the two are totally different things. Investing in GBTC, or in the proposed ETF, is like investing in lottery tickets; whereas investing BITO is like investing in a lottery ticket shop. Both are morally reprehensible, since they are economic parasites that take money mostly from uneducated people without providing anything of value in return; but, in a strictly financial view, the second makes sense, the first doesn't.

Indeed, this "consistency" argument by the Grayscale lawyers is clearly a preemptive attack, intended to deflect attention from fact that it actually works against them: since the SEC has previously denied all proposals of bitcoin spot ETFs, consistency requires that it reject Grayscale's, too...

And, finally, many of the letters show that sender did not understand the nature of BITO. Some seem to believe that it will hold (and be backed by) actual bitcoins; others think that its market price will be tied to the BTC price; others confuse investing in BITO with themselves buying BTC futures contracts. Naturally Grayscale does not seem to have made any effort to educate them on this point.

Approval in other countries is not relevant

Many other countries have looser regulations, or more inept or corrupt regulators. Not just in finance, but in all areas. "The US should lead the world in crypto" means that it should have more restrictive regulation, not less. Such as banning the toxic garbage that is crypto.

Grayscale should simply liquidate the fund

A better way for Grayscale to relieve the GBTC investors of the discount loss is to liquidate the fund. Namely, Grayscale buys back all the shares, giving each holder either the BTC equivalent of each share, as above, or the NAV in dollars, without discount, obtained by selling the BTC. It can spread the sale over a few months in order to avoid hurting the BTC price.

This alternative would be good for investors, but obviously not good for Grayscale -- that will lose the no-sweat revenue from the 2% maintenance fee (currently about 380 million USD/year). Naturally Greyscale did not mention this possibility in the spam-soliciting letter.

GBTC investors in the EU will be unable to invest in the ETF

According to the letters, GBTC has about 850'000 investors, or which only about 600'000 are in the US. Indeed, many of the letters are from foreign citizens or US citizens residing abroad.

A few of the letters claimed that, being, if the conversion happened they would not be allowed to invest in the ETF. I have been told that indeed that is the case, at least for citizens or residents of the European Union.

Yet, Grayscale apparently did not mention this issue in the messages that invited GBTC investors to spam the SEC in support of the change -- neither admitting nor denying it.

Conversion to ETF was neither promised nor expected

Many letters seem to imply that a conversion of GBTC to an ETF should be a natural progression, that the SEC is only delaying. But such a promise should never have been made. But when investors choose GBTC, they had no reason to expect that such conversion would be requested, much less approved by the SEC. Grayscale had better not have fostered that hope in any way, even tacitly, before the present filing.

Notable letters

Here are some of the letters that caught my attention for one reason or another.

Letters against the conversion

https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-301144.htm @ "Crypto is out of control" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-300351.htm @ "I'm writing to ask that you do not give into industry pressure, and you *reject* the grayscale ETF. Please do not allow the crypto the chance to sink its teeth into grandma's pension." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-299954.htm @ "Cryptocurrency is an illegal security [...] If the SEC does not immediately come out and declare that cryptocurrencies are an illegal security under the 1934 Securities and Exchange Act, OneUniverse, the Universal Church of God, will bring a class action lawsuit against the SEC and the US Government for [...] not taking appropriate responsibilities in declaring cryptocurrency to be illegal when it was first issued. Bitcoin, an example of an illegal currency that appreciates so no one is motivated to invest in small businesses. [...] This email will be posted on One Universe website" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270171.htm @ "Please do not approve any crypto ETFs, all of these schemes would further enrich scammers only." (That is the whole letter.) https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270736.htm @ "digital currency is and will become an exploitable financial playground for criminals and scammers [...] I personally have experienced a crypto scam and now know first hand how the system can be used effectively to perpetuate fraud and dishonesty." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270925.htm @ "In the dozen+ years of cryptocurrency existence, it has found no productive niche in the world economy. It's not a useful store of value. It's not a medium of exchange. It's pure speculation and gambling. Perhaps its one functional use is to enable monetization of cybercrime." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-280356.htm @ "The reasons why you rejected previous ETF proposals are still valid and should be sufficient to deny this one (and any future ones) as well. Needs more regulation." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286540.htm @ "Bitcoin is, at best, a digital collectibles and at worst a digital scheme to syphon money out of real productive economy in to private speculative gambling. A significant portion of players in the field are deceptive, if not openly dishonest." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286517.htm @ My second letter. Argues that if the SEC allows this ETF, it will have to deal with thousands of similar requests for ETFs of other cryptocurrenceis. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-294165.htm @ "I'm against all 'synthetic securities'. I've heard a handful Bank CEO's describe Bitcoin and they've all had different answers. If it doesn't make sense then it's not real. [...] Really finance and bitcoin should fall under fiction writing class 101." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269004.htm @ "Bitcoin and other digital currency is tool for crime and extortion. If the SEC encourages the creation of digital currency products, you will be complicit in the promotion of drug trafficking and extortion." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20117200-268419.htm @ "There is no need for a BTC spot ETF fund other than to make a few whales rich who need American money to maximize their returns. BTC is a pump and dump, manipulated asset. Don't give whales our money. [...] BTC is a zero sum game and it's backed by nothing. It's touted all over the Internet as an 'inflation hedge', but it dropped over 40% after a record CPI report in late 2021. Also, a few Elon tweets in the Summer of 2021 made it drop over 50% [...] Please see the enclosed links revealing fraud and manipulation with BTC [..]" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20116503-268037.htm @ "Bitcoin (BTC) at the moment is plagued by fraud, manipulation, wash trading, and overall criminal activity. Tether (USDT), a highly controversial dollar stablecoin with dubious backing, is responsible for more than 70% of all trading activity in Bitcoin and many other cryptocurrencies. [...] much like a pyramid scheme, but worldwide [Conversion], or allowing another spot Bitcoin ETF, would be a huge mistake and only make this world's largest ever ponzi scheme, even larger and pose an even greater risk to the financial system" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20116058-267778.htm @ "At one time my GBTC holdings were worth 2.1 million dollars, but today only about 1.1 million dollars. [...] I am getting old. All my stock is in GBTC. [...] My only experience was with the gold ETF, it seemed fine except for a higher taxable gains rate, which I don't want for GBTC because I would like to make periodic sales over my retirement to pay my expenses. [...] I understand there was a time when new investors couldn't sell on the open market for 6 months. But those new investments stopped long ago [...] So why the negative net asset value? [...] Silbert keeps innovating these new companies and trusts but he doesn't seem to have his eye on the ball at GBTC. [...] I want to trust him, but I'm not sure I do." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-267760.htm @ "There is still way too much bitcoin price manipulation done by Tether and other stable coins on unregulated crypto exchanges like Binance and Huobi. Until these stable coins are highly regulated, or banned, they will continue to manipulate the price of Bitcoin which makes it impossible to gauge fair market value. Most retail investors do not understand the scheme of how endless stable coin printing artificially manipulates the bitcoin price. A spot ETF would be an absolute disaster!" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20114964-267257.htm @ "hello dear under funded regulatory body, we salute you for your work [...] no bitcoin etf before a tether audit [and] a pokemon card etf [and] the end or regulation of stablecoins [...] maybe think of bitcoin as a micro cap cash transmitting entity multi listed on un regulated (not to say outright criminal) exchanges dispersed around the world, with 2% of the holders, who bought early, controlling the lion share of the volume [...] kyc is near impossible on all bitcoin transactions [...] the early holders are desperate for new liquidity to get out (the ethereum foundation have sold at each all time high)" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-295123.htm @ One of the two iconoclastic "Bicoin Uncensored" commentators. He's actually in favor of the ETF but tries to use 'reverse psychology' or sarcasm: "I am Joshua Unseth, a 35ish year old African Americanish male who loves Bitcoin [...] As an avid collector of things such as Norman Borlaug pictures and Beanie Babies, I have gained an interest in Bitcoin and would like to add as much as I can of it to my personal collection. [...] it is imperative for the purpose of equity and fairness that you continue encouraging GBTC to trade at a discount of more than 30%. It is well worth the 2% fee, at the moment, to buy coins at a price that is slightly above $20,000. It is my sincere belief if you deny this request, the discount will become even steeper, and I would appreciate the opportunity to acquire coins at a NAV closer to (perhaps) even 50% cheaper than I could on the open market. [...] I am certain that a majority of the people who are writing you will write in support of your approval. [...] But I ask that you reject these arguments. [...] it is my fear that Bitcoin will go up if an ETF is approved [...] Please do not destroy this perfectly reasonable 30% discount simply because it would be 'good' for people." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-295098.htm @ "I am vehemently AGAINST [...] I strongly believe in Cryptocurrency and Crypto ETFs. I also know that Grayscale is not the sponsor that should handle such an offering. [...] After purchases, I noticed that Grayscale's fact sheets (sources attached) for $ETCG and $BCHG stated: 'The Product will not generate any income and regularly sells/distributes digital assets to pay for its ongoing expenses. Therefore, the amount of digital assets represented by each share will gradually decline over time.' This statement alone makes their investment program unsuitable for any investor." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-293988.htm @ "Bitcoin is in a turf war with itself and competing protocols and involved in many lawsuits. Grayscale should not be doing as much 'business' as it already does, let alone expand. If anything, you should probably move to tame the 99% of the crypto market, which is either directly or indirectly involved in criminal activity. But I understand it was difficult to foresee that mankind did not need another 500 Dogtokens (this was sarcasm)." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292578.htm @ "Do NOT support the conversion of Grayscale Bitcoin Trust [...] This is a an ETF that has no intrinsic value and will cause massive losses for the common person." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292417.htm @ "I am an ordinary citizen and have no interest in Bitcoin or any other Crypto. I [...] have seen so many posts promoting Bitcoin [...] SEC should not allow GBTC or any other entity to convert to ETF. This would make ordinary citizens gamble on these highly volatile tokens." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292311.htm @ "I am NOT in favor [...] I believe individuals should custody their bitcoin directly or in a collaborative custody fashion, similar to cash." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290046.htm @ "... Bitcoin is a fictional asset. This alone is obviously disqualifying. ..." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-288995.htm @ Short but to the point. "Permitting a Bitcoin ETF essentially legitimises what may be the largest fraud ever perpetrated in history" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20116363-267983.htm @ "Tether (USDT), counterfeit digital dollars on a huge global scale, is responsible for more than 70% of all trading activity in Bitcoin and many other cryptocurrencies. It is these fake digital Tether dollars that are most responsible for setting the dollar price of Bitcoin, not real dollars as many falsely assume." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20118544-271427.pdf @ From lawyer firm Ropes & Gray on behalf of an investor. Points out that Greyscale bought $700 million worth of its own GBTC shares, at the 25% or whatever discount, and is authorized to buy $1.2 billion. If GBTC is converted to an ETF, Greyscale would then be authorized to sell the corresponding bitcoins at the market price, thus making some $200-350 million in profit -- at the expense of the suckers who sold them the shares at discount. Argues that the conversion should be denied until Grayscale starts a redemption program, or compensate investors in other ways. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20125326-284782.pdf @ This one says that he invested in Grayscale's ETH fund (ETHE) not in GBTC. But he fears that if GBTC becomes an ETF, then ETHE will become one too -- and he is AGAINST that since he lives in Ireland and would not be allowed to invest in the ETF from there. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-261907.htm @ A very long letter. Many links to sources. The arguments are (1) bitcoin is highly concentrated, (2) it is being pumped by Tether Inc. and others, (3) the pump will affect the ETF price index, which is to be derived from prices at the exchanges. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-272115.htm @ Accuses Barry himself of manipulating the price with social media messages, in particular with a tweet "Big week ahead" that (the author says) caused the price shoot up 10%, leading to the $69k ATH. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-280061.htm @ "As you and other regulators have noted repeatedly, Bitcoin trading is almost entirely constituted by market manipulation of various sorts, and depends on that market manipulation to keep cash flowing into the system." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-280089.htm @ My fist letter. "The reasons why you rejected previous ETF proposals are still valid [...] if you need any other reasons: 1. BITCOIN IS A TOOL OF CRIME [...] 2. BITCOIN IS A HUGE PONZI SCHEME [...]" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-280114.htm @ "None of the conditions current during the previous SEC rejections of this fund have been remedied. This is a terrible idea that could further legitimize a ponzi scheme" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-280357.htm @ "It's a tool for criminals. It's massively manipulated. Tether and stablecoins are a terrifying threat. Bitcoin and crypto in general is as close to a massive Ponzi as we've seen recently" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-284043.htm @ "The constant pressure to approve a spot Bitcoin ETF exists because Bitcoin is a negative-sum game - Bitcoin whales need to increase the flow of dollars in so as to have dollars to withdraw. The SEC should not pander to them." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-285205.htm @ "I do not want GBTC to be converted into an ETF. Sorry" (That is the whole letter.) https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-285675.htm @ Wants an ETF but thinks it should be an independent enterprise: "the company chose its structure and trading format from what was available. Should it desire a different, permitted format, then it can close the current and open the alternate." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-285965.htm @ "I vote NO to EFT conversion" (That is the whole letter.) https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286251.htm @ Wants a bitcoin ETF, but not Grayscale's. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286533.htm @ "Please do not allow GBTC to create a spot Bitcoin ETF. The Bitcoin market is manipulated by offshore exchanges." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286551.htm @ With original argument: "I am concerned that short hedge funds will be able to manipulate that price of the ETF BTC product so that the price is not directly related to the performance of the underlying BTC." Would that be meta-manipulation? https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286572.htm @ "The constant pressure to approve a spot Bitcoin ETF exists because Bitcoin is a negative-sum game - Bitcoin whales need to increase the flow of dollars in so as to have dollars to withdraw. The SEC should not pander to them." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286591.htm @ Unfortunately with no arguments. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286609.htm @ "I feel as though cryptocurrency is damaging to society as a whole [...] Acting like a pyramid" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289064.htm @ Takes a quote from "Madness of Crowds" book and replaces "tulips" by "bitcoin" throughout. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292474.htm @ "Dont allow these Ponzi schemes to destroy our country Nobody needs these unregulated, untrustworthy, unaudited asset classes."

Letters showing the use of GBTC for IRA and 401k accounts

https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269320.htm @ "I own over 17,000 shares of GBTC in a variety of retirement accounts" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269431.htm @ "I have a significant portion of my retirement account in this fund" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270097.htm @ "I hold ~3/4 of a Bitcoin in GBTC in my Roth IRA and it's currently trading at the equivalent of 0.58 Bitcoin." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270419.htm @ "I have a large percentage of my retirement account invested in the Grayscale Bitcoin Trust" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270271.htm @ "My wife and I have invested regularly in GBTC in our Roth IRA with Charles Schwab Brokerage." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269953.htm @ "I have BTC through GBTC in my IRA account and a Roth IRA account. This is about 5% of my total portfolio. [...] For me it is a hedge against bad things happening" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270733.htm @ "I am a 45- year-old mother of 2, from Phoenix AZ, who invested a significant amount of my family's retirement funds to GBTC" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271070.htm @ "I live in Illinois and have GBTC Grayscale in my IRA." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271111.htm @ "I am a retail investor and while planning for retirement in May 2020 I invested a sizeable amount in GBTC. At the time it was selling at a premium to NAV" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271266.htm @ "I own GBTC in a Roth IRA" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271562.htm @ "Grayscales bitcoin product is the most widely invested bitcoin trust within American 401K's." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271770.htm @ "I have been a heavy investor in GBTC in my 2 retirement accounts" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-273617.htm @ "There are hundreds of thousands of normal American investors in GBTC. I am one of them via my IRA." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-273757.htm @ "I'm a retired naval officer and have significant exposure from my retirement accounts in GBTC." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-273781.htm @ "I discovered Greyscale trusts in 2019, and have been steadily accumulating GBTC and other digital asset products in my retirement account." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-278734.htm @ "This is important as many of us have put a portion of our retirement funds into GBTC." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-278710.htm @ "I own shares of GBTC in my IRA account and intend them to be a long term hold." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-279061.htm @ "I am an experienced investor that has invested a sizable amount of my retirement IRA account into GBTC, which at the time was trading slightly above the spot price or Bitcoin" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-279714.htm @ "I am investor in GBTC in my retirement account" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286354.htm @ "I personally hold shares of GBTC in my IRA account" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286349.htm @ "I personally hold shares of GBTC in my IRA account" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289634.htm @ "I personally hold shares of GBTC in a tax-advantaged retirement savings account" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269190.htm @ "I purchased GBTC at a premium and now it's trading at a discounted rate. Please keep in mind this is held in a ROTH IRA retirement account." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-268949.htm @ "I've placed my retirement in GBTC." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271869.htm @ "I live in New York and have GBTC in my IRA account" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269245.htm @ "I'm at the point where I'd rather just take my $6k annual Roth contributions to Gemini and buy the underlying." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269709.htm @ "A significant portion of retirement funds are in GBTC." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20116571-268049.htm @ "I have a retirement account that I save judicially [sic] every year for. I buy sp500 index fund and GBTC." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20116601-268082.htm @ "I am an individual investor that holds GBTC in my IRA." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20116191-267872.htm @ "The reason myself and many other investors were initially drawn to the GBTC is due to the ease of owning it in an IRA account." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-267813.htm @ "I have invested small pieces of my 401K in GBTC and in ASTR. ASTR has proven far more volatile and literally crashed last week! If Bitcoin crashed 80%, so what?" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20116192-267873.htm @ "I was excited to discover that GBTC was available in my 401k and so I purchased shares as a vehicle to invest in bitcoin. Unfortunately, this investment has performed poorly" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-267880.htm @ "As an investor that's held GBTC in my Roth IRA since 2018" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20116193-267874.htm @ "I have placed a significant portion of my retirement savings into GBTC fund" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-267852.htm @ "I am not an accredited investor. I work long hours. I pay taxes. I pay my mortgage. [...] I dollar cost average into my investments hoping that one day I can pursue my passions without financial stress" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20116024-267730.htm @ "Own GBTC in a ROTH IRA" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-296360.htm @ "My investment in GBTC is held in an IRA account" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-294651.htm @ "I was raised by a single mother, sometimes working up to 3 jobs to provide for her three children. I have worked hard, as other Americans, [...] have been able to invest into GBTC with a portion of my IRA." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-294483.htm @ "I have been a long term holder of the GBTC in my IRA" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-294019.htm @ "I currently hold GBTC in my Fidelity IRA and previously held the Coinshares XBT until it was frozen for US investors by the SEC." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292730.htm @ "As a shareholder in the GBTC via the brokerage link attached to my 401K retirement plan" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292609.htm @ "I'm in my 50's and I hold index funds in my retirement accounts...along with GBTC." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292229.htm @ "As a long time investor in Bitcoin and GBTC (in our IRA since we cannot buy Bitcoin directly in an IRA)" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291546.htm @ "I personally hold GBTC in my 401k and know of family and friends who do as well." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291885.htm @ I max my 401k out every year. I max my wife's and my ira every year. I own rentals, I own BTC and diversify in collectibles (rare game used sports memorabilia). [...] I'm not the most sophisticated investor, but I'm a hard working self made multimillionaire." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292104.htm @ "I purchased GBTC in my IRA well over a year ago" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292334.htm @ "A significant portion of my 401K portfolio has longterm allocations in GBTC, ETHE, and LTCN." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291621.htm @ "I already own GBTC in my 401k" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292318.htm @ "I [...] am nearing retirement age. Much of my wealth is in retirement accounts, making it difficult for me to invest directly in BTC. GBTC gives me some exposure" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292335.htm @ "My 401K plan (Schwab Self Directed) allows for my investment in GBTC already" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292322.htm @ "I have my retirement account heavily invested in GBTC" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289477.htm @ "I own some Grayscale Bitcoin Trust (GBTC) shares, which I hold in my Fidelity Brokerage account. I'm employed as a patent attorney and I have a variety of investments which serves as my 'nest egg' for my family. I have about 5% of my assets in cryptocurrency, and presently hold the cryptocurrency in GBTC, Coinbase and Paypal." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289576.htm @ "I am a very small investor who has a long term investment in GBTC via my retirement fund." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290022.htm @ "I have held GBTC in my IRA since I bought it at $4.31 a little over four years ago. At the time, it was the only way to get exposure to Bitcoin in my Fidelity IRA" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290541.htm @ "I want to be invested in bitcoin in my retirement account. Currently I do that with GBTC, but the discount to NAV is poor." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289907.htm @ "I hold Grayscale in my self-directed IRA account." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289724.htm @ "Much of my retirement fund has been invested in Grayscale Bitcoin Trust to avoid insecure trading of bitcoin" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290870.htm @ "I have GBTC in my fidelity retirement account and I am for a change of the trust to a spot BTC ETF." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289876.htm @ "I am a resident of Tennessee, and I hold shares of GBTC in an IRA." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289932.htm @ "More importantly to me personally is that Vanguard recently started prohibiting me in trading GBTC in my retirement accounts because it is traded on the pink sheets. Allowing it to become an ETF would mean that that prohibition would end and I could trade in this financial vehicle again." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290784.htm @ "A great deal of our retirement savings is [...] locked into a fund that many of us assumed would be an ETF by now." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290922.htm @ "Initially GBTC was the only avenue to reliably trade crypto currency where I reside, New York State. [...] This was the only avenue I had to allocate a small portion of my IRA to bitcoin." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289506.htm @ "Conversion to an ETF would also allow me to continue to buy GBTC at Vanguard, which recently stopped allowing OTC stocks to be bought through their brokerage." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289916.htm @ "I am currently allocating a portion of my retirement into Bitcoin and am being forced to use offshore options." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290864.htm @ "I bought into this Trust NOT for trading purposes, but as the only way (at the time) to buy and hold BTC in my retirement account." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289505.htm @ "I hold the GBTC Grayscale Bitcoin Trust in my IRA." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290831.htm @ "I use GBTC in my retirement funds." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289958.htm @ "I'm an investor and I own the GBTC in my IRA." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289660.htm @ "I hold GBTC, Grayscale Bitcoin Trust (OTCQX: GBTC), in my retirement account" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290442.htm @ "I have a bachelors degree and an MBA with a concentration in Finance [... I am] holding Grayscale Bitcoin Trust in my self managed retirement portfolio." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290468.htm @ "I am a union aircraft mechanic from Oregon and [..] a holder of GBTC, and this issue affects me personally." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291228.htm @ "I have owned GBTC shares since 2020 through my IRA" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291231.htm @ "As a long term GBTC shareholder via my IRA (since 2019) ..." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291325.htm @ "I want to convert GBTC to a spot ETF so I can have a better bitcoin proxy in my 401k account." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-279183.htm @ "I have been investing in Bitcoin since 2015 and I am now 52 years old. My whole life, I lived paycheck to paycheck and had many sleepless nights. Bitcoin has changed my life." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-279845.htm @ "I converted my TSP IRA and 100% invested in GBTC two years ago with my 401k funds after retiring from federal service." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-278534.htm @ "I've been an investor in the Grayscale Bitcoin Trust (GBTC) in both my taxable brokerage and tax-deferred retirement accounts since 2016, and have been a bitcoin investor since March 2013. [...] Over 80% of my net worth is tied up in various flavors of the asset. I come from a working class background and all of my net worth is from invested income I have earned through employment." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286498.htm @ "I own GBTC in my retirement account (Traditional IRA), alongside Tesla Stock. My being able to retire at 67 is based on these two assets that I own. This is my only form of savings, and I have no other savings, thanks to COVID and layoffs. I have burnt through my savings." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289121.htm @ "I have also through my 401K plan at work been able to buy shares of the GBTC trust." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289151.htm @ "... I am 86 years old and hold a lot of this stock. I want to sell this stock 'at its underlying value' in order to continue my retirement. ..." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289160.htm @ "I invested a substantial portion of my 401k savings in GBTC in early 2021." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289529.htm @ "I hold GBTC in an IRA which I have contributed to for over 10 years in my career as a pharmacist." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290599.htm @ "I am a GBTC unit holder. I hold units individually, in my IRA, and for a family LLC." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290683.htm @ "A significant portion of our retirement savings is tied up in an asset you have been reluctant to approve as a spot ETF." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290862.htm @ "I own this holding in all of my retirement accounts" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290961.htm @ "I am a disabled purple heart veteran [...] The above is grayscales pre-canned msg but in my own words I'm buying GBTC for my retirement account which is red (over last 3 years) I just started investing because I have never had a 401k and I'm over 40 years old. I have purchased QQQ which has lost more money than BTC. SPACS I bought have lost more than BTC. If it wasn't for the GBTC discount, I wouldn't be losing money." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291028.htm @ "My wife and I both own GBTC in our IRA's and I have been forced to purchase a Bitcoin futures mutual fund in my 401a and 403b." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291536.htm @ "I invest in $GBTC to gain exposure to Bitcoin through my IRA" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291574.htm @ "GBTC gives me the opportunity to invest a small portion of my 401k retirement funds into the most established asset" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292326.htm @ "I own this trust in my 401(k)" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291783.htm @ "I wanted to get a reasonable amount of Bitcoin exposure in my 401k and GBTC was the only option available" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291434.htm @ "I continue to be an Illinois based investor in GBTC within my [...] 401k holdings." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291572.htm @ "I have owned GBTC for over 2 year in my IRA account."

Letters that want bitcoin available for IRA and 401k accounts

https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269296.htm @ "[I] am a trustee to a large Trust. I would like to diversify the investments with some exposure to Bitcoin but have limited options other than the currently listed Grayscale Bitcoin Trust." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270385.htm @ "I [...] am able to self-custody my bitcoin, but my mother, aunts, grandparents, etc., don't have that ability or desire to learn. Additionally, many pensions are not allowed to invest in the fund" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270507.htm @ "As a retail investor looking to allocate a portion of my retirement savings in bitcoin denominated assets [...]" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-278672.htm @ "It would allow me to diversify my 401k" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-279474.htm @ "I am a disabled vet and would like to allocate some of my retirement into a spot bitcoin ETF" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286371.htm @ "Millions of people are waiting for an opportunity to gain exposure to cryptocurrencies through their regular investment accounts." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286238.htm @ "I write to you as a GBTC shareholder [...] I am not wealthy and worked hard for what have earned. " https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269545.htm @ "I currently hold the GBTC via OTC in one of my retirement funds. [...] I would MUCH rather just invest in crypto via my existing retirement accounts (such as Vanguard, Raymond James, TD Ameritrade)." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-267792.htm @ Very long letter with footnotes. "The majority of my family's savings is in a self managed IRA custodial by Charles Schwab. When I learned of Bitcoin [...] I naturally inquired about holding it in my IRA. I was disappointed to find out that I could not hold this digital asset in my account. Thus, I did the next best thing. I moved the majority of my savings into GBTC since it was as close as I could get to an ETF." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20115415-267447.htm @ The author signs as CEO of EJC Ltd: "A spot ETF would result in an immediate allocation from our companies pension fund." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20113918-266112.htm @ "This ETF would allow millions of people to invest in bitcoin through their IRA accounts. I personally would love to have direct bitcoin investments in my IRA." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292734.htm @ "I want to invest a % of my 401k rollover in Spot Bitcoin" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291925.htm @ "my employer sponsored 457b currently does not allow me to buy GBTC, I am hoping that a change to a Spot ETF will allow me to purchase these shares" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291682.htm @ "I would like to be able to gain exposure through my company designed retirement account." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291667.htm @ "In 2021, I cleared out a portion of my 401k resulting in a significant taxable event just so I could have those funds to purchase bitcoin." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291549.htm @ "An ETF will allow standard 401k and brokerage accounts to access an asset that is useful and scarce. For years I have been invested in GBTC" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292341.htm @ "As a Financial Advisor for a major firm, our clients keep asking about bitcoin. This gives us an opportunity to give them a small allocation to the space even if only 1-2%." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291509.htm @ "Providing a Bitcoin ETF would allow me to invest in Bitcoin through my Roth IRA and have it grow tax free." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290580.htm @ "I am retired, and not a highly sophisticated investor. Yet, I do want to participate in the direct bitcoin market." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290765.htm @ "It is crucial for this asset to be available for investors who want it in their retirement and other accounts." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289494.htm @ "opening up a spot ETF [will allow many investors to] buy within their current financial institutions will allow them access to this investment option" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289668.htm @ "Most of my retirement is in my IRA, and a Bitcoin Spot ETF would be the best way for me to get exposure." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289728.htm @ "[Conversion would] allow safe and easy opportunities to invest in Bitcoin via standard retirement vehicles such as your 401k or IRA." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289492.htm @ "to be available in retirement accounts like ROTH IRA" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290614.htm @ "[I] want to be able to invest in bitcoin as directly as possible through my retirement accounts." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290329.htm @ "I teach tennis at a country club for a living [...] investors like myself who wish to hold GBTC in a roth IRA for retirement at exposed to unncessary risk and lack of protection as GBTC trades below NAV." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290233.htm @ "I want a small exposure to Bitcoin in my IRA's in addition to some direct ownership through cryptocurrency exchanges." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290130.htm @ "I want to allocate to my 401k and Raymond James won't even allow me access to GBTC." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-288550.htm @ "this asset will allow us to prepare for retirement via 401k trade BTC without discount" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291553.htm @ "As someone who uses investing to supplement my middle to lower class income I would really like to be able to invest in a Spot Bitcoin ETF" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291266.htm @ "I [...] would like a small, limited exposure to Bitcoin in my IRA through Graysacle" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291641.htm @ "I would also love setting up a bitcoin fund for my kids and retirement as part of my stable portfolio."

Letters that insult, threaten, blame, or patronize the SEC

https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-298062.htm @ "Please do your due diligence and learn more about how cryptocurrencies can help the average person [...] An algorithm can't be racist. A bank can and has been!" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-297432.htm @ "Are you folks willing to lose all credibility as is strikingly happening with other government agencies?" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269103.htm @ "Gary may have 'taught' blockchain, but it is clear he does not understand cryptocurrency." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269849.htm @ "As a public servant Gary Gensler you should be ashamed [...] Stop helping your friends [...] and just approve the god damn ETF application." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269051.htm @ "politics has completely infected the mission of the SEC. [...] Frankly disgusted" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270416.htm @ "I know [Gary Gensler] understands that Bitcoin is unique in comparison to 'crypto'" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270276.htm @ "Gary Gensler only helps the rich get richer" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270278.htm @ "The SEC has recently showed they only care about power, money, and protecting the banks and big money. The SEC's job is not to regulate by enforcement ie. The Ripple case." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270201.htm @ "The world is looking at how the SEC and Gary Gensler, the longtime Goldman Sacks alumni, can be independent of the banking and financial industry." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271066.htm @ "This is a travesty. This is an SEC [sic] should be ashamed of its self!!" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271608.htm @ "If we wanted a nanny state we couldn't have chosen any better than you." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271957.htm @ "I think there is something shady about not having this already approved. Is it that the big banks are not paid off yet?" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-273601.htm @ "In August of last year Chair Gary Gensler, stated 'Further, it [crypto assets and blockchain technology] has been and could continue to be a catalyst for change in the fields of finance and money.' Based upon that it sounds as of he is resigned to that fact that it shouldn't get regulated out of existence." But, ahem, a catalyst is a substance that promotes a reaction, but does not get used or included in the final product... https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-273606.htm @ "Even your own SEC Commissioner Hester Peirce can't believe how long this is taking and states the reasoning for denying a spot ETF is outdated" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-278674.htm @ "Gensler's behavior is shameful & genuinely makes me question why I bother to vote." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-279047.htm @ "GBTC's discount and fees are obscene which are a direct result of the SEC's adversarial disposition towards spot Bitcoin and GBTC." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-278961.htm @ "Boys, let's stop playing the games. [BITO] only allows your buddies (yes, I know, your fellow investment banker buds) to profit." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-279250.htm @ "Please stop the fear mongering around Bitcoin ETFs and crypto." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-280129.htm @ "Under the caption “An Old Dog Learning New Tricks”, I have carefully watched Professor Gensler's MIT course on blockchain technology and proof of work protocol [...] If you doubt the integrity, vibrancy, and depth of the BTC spot markets, please watch Anthony Pompliano's [...]" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286266.htm @ "On a personal note, Mr Gensler, I watched your MIT course and it was my first introduction into this new asset class. I know you believe in this new digital class because you wouldn't waste your time teaching a course on a meaningless topic. When you asked the class the question early on about how many were already into this digital space, you saw the majority of the MIT students raised their hand" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-288309.htm @ "Of course it appears to a fair number of observers that there is an unspoken reason for your continued disapproval of these ETFs" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290219.htm @ "Hey SEC, how are you doing this good day? [...] I am waiting for your answer have a good day me lord." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269588.htm @ "If Gensler cannot run the SEC to the letter of it [sic] charter, he should resign." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-268944.htm @ "WHAT EXACTLY ARE YOU WORKING FOR? [...] YOU NEED TO DO THE RIGHT [REDACTED] THING AND APPROVE THIS. APPROVE IT BEFORE YOUR VAN ECK FRIENDS AND YOUR BLACK ROCK THIEVES [...] THIS WAY YOU DON'T ROB ANYONE IN THEIR PRIVATE PLACEMENT ANYMORE WITH THE 2% NONSENSE [...] THE SEC IS LAUGHED AT AS ALLOWING CRIMINALS TO GET AWAY WITH EVERYTHING AND NEVER DOING THE RIGHT THING [...] AND JUST TO LET YOU KNOW, AS SOMEONE WHO ACTUALLY WORKS IN THE FINANCIAL INDUSTRY WHO'S HONEST WHO'S NEVER [REDACTED] ANYONE OVER FOR MONEY I THINK YOU ARE ALL PIECES OF [REDACTED] AND SHOULD BE DISBANDED YOU HAVE ZERO!!!!!! INTEGRITY!" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269815.htm @ "Thank God The SEC, The FED and The US Treasury are not in El Zonte 'protecting' investors." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269039.htm @ "I support Hester Pierce in her position that it makes no sense to approve a futures based ETF while denying a spot ETF." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269396.htm @ "Having immersed in Gary's courses I came to have a lot of respect for his deep and balanced take on Bitcoin. I now feel betrayed" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269315.htm @ "Please prove you are not in the pockets of banks" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271867.htm @ "You guys are too arrogant and out of touch with the public who pays your wages. [...] A non-canned email response would be appreciated. Gov owes that to us tax payers who provide your food and clothing." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270006.htm @ "Dear SEC, Quit being a little fiat bitch." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269432.htm @ "'Dear' SEC." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20117364-268632.htm @ "Should the SEC be put in charge of Major League Baseball, all MLB games would be postponed indefinitely due to the threat of rain, somewhere, at some time." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-268562.htm @ "The American dream is dead. Killed by self centered, arrogant, money and political posts grabbing bureaucrats ('Crypto mom' being excluded from this, of course). Had there been an institution like SEC just a few hundred years ago, California would still be a barren land [...] I represent over sixty investors from four different countries who have been purchasing GBTC since the early 2018 and are angry and frustrated by helplessly watching how bitcoin and GBTC are manipulated, destroyed and constantly, systematically sabotaged by idiotic liquidations of laveraged futures the SEC so elegantly allowed thru CFTC and one ancient law dating back to the age of dinosaurs, bronterocs [sic] and senile mummies like Dimon, Buffet, Munger, Schiff and Roubini. SEC - as a symbol of total hypocrisy – has in fact never protected any investor when it did matter the most [...] our lawmaking imbeciles past & present like Trump, Pocahonta, Shermann end endless others [...] Like Matt Damon has already said so many times: 'Fortune favors the brave'" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20117101-268322.htm @ "This organization needs to be under a microscope your main purpose is [...] not to impose ridiculous restrictions for political and financial gain. DO YOUR FIN JOB AND APPROVE THE GBTC etf IMMEDIATELY. Your organization is the biggest waste of tax payer dollars ever seen and now your costing regular ppl thousands with your manipulation and knuckle dragging." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-268549.htm @ "Hi Gary, I am a 75 year-old retired Xerox Executive who has enjoyed listening to the 30+ hours and 24 lectures presented by you at the MIT [...] a phenomenal teacher, exceptionally brilliant and kind hearted [...] I also enjoyed the 20 March 2019 fireside chat between Hester Peirce and yourself [where both of you] expressed qualified support for approving a Bitcoin ETF... [...] Commissioner Peirce even expressed her feeling that the SEC did overstep its statutory authority by not approving a Bitcoin ETF. [...] Gary, I am also aware of your position that you won't support a spot Bitcoin ETF until there's a robust regulatory framework in place around crypto exchanges [...] you mentioned that you would support the creation of a single National Exchange for crypto [...] So I am now asking you the same question you asked Commissioner Peirce... WHEN will we have a National Exchange capability for crypto[...]?" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20116493-268027.htm @ "Why does an unelected official have this much power and sway over financial markets? Who put this guy in charge? How do we get him removed???? " https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20116573-268052.htm @ "It seems the SEC has abandoned its mandate on denying all bitcoin ETFs and is instead de facto protecting the interests of the status quo, the banks." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20116084-267807.htm @ "It is time to put to bed the rumor that the only reason that the SEC has not approved a spot-market bitcoin ETF is because the SEC regulates the futures market and not the spot-market, resulting in a policy based on some kind of bureaucratic turf protection" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-267808.htm @ "Please stop pretending that you are protecting average investors. We know who is benefiting from the lack of a spot BTC ETF and we exactly know who you are serving." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-267762.htm @ "The fact that there are a few human beings that are limiting my ability to invest in something I've spent thousands of hours studying is not small investor protection [...] shows how hypocritical the current stance is" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20116039-267756.htm @ "DO YOUR JOB and innovate the SEC before you get left behind." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20115410-267440.htm @ "The stated delays seem to be more about regulatory capture [...] the SEC refuses to provide straight answers that aren't hidden behind political and lawyer verbal gymnastics. [...] the lies you say on tv [...] you have failed to do your job adequately" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20115405-267433.htm @ "The SEC is corrupted by the interests and positions of large financial institutions." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-266075.htm @ "The SEC IS GUILTY OF ALLOWING THE MANIPULATION OF THE PRICE OF BTC. [...] The SEC IS GUILTY OF RESTRICTING THE FUTURE WEALTH OF US CITIZENS. [...] ARE YOUR HANDLERS DONE LOADING THEIR BAGS YET?" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-280167.htm @ "It is criminal that you clowns continue to block Bitcoin ETFs like GBTC request and others" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-9370455-262047.htm @ "Delaying the approval of a spot ETF in the name of investor protection will only continue to harm US investors. As Commissioner Pierce recognized: ..." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-261108.htm @ "I realize that you would like to use ETFs as leverage to force compliance rules on bitcoin exchanges to identify and report fraud and price manipulation to help insure greater investor protections." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-296321.htm @ "Your continued denial of ANY etf is criminal, if this goes to court I hope they throw the book at you." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-296163.htm @ "Stop thinking only of yourselves and your own financial portfolio!!" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-295900.htm @ "Because of the total inaction on the part of those of you at the SEC [...] everyday investing americans are being screwed over by all of at the SEC. Yes, you heard that correctly. You are to blame. You are screwing us, not Grayscale." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291601.htm @ "I am personally investing in GBTC in my traditional retirement account [...] I spent many hours to understand including SEC chair, Gary Gensler's MIT blockchain classes, yes all of them!" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292248.htm @ "I operate a food truck [...] and I'm an investor in Greyscale Bitcoin Trust. [...] How is [SEC's rejection of Bitcoin ETFs] not an utter hypocrisy? I think the real reason for your denial is evident to everyone and will be very evident to the courts if you once again fail to do your job" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292402.htm @ "The paradisial [sic] nature of forcing US based investors to take a loss in the name 'protecting' us is a laughable claim; now please move out of the way of the markets choices that you are openly hindering." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291402.htm @ "You are a joke of an organization and you need to approve a spot ETF instead of wasting tax dollars circle-jerking billionaires at the detriment of a growing sector of the population." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292028.htm @ "Just STOP ruining your reputation and as trustworthy entity' with outdated facts, and unrealistic 'safety concerns'. Bitcoin adoption is happening faster than you could keep yourselves irrational over time." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289648.htm @ "Under the last few chairmen, and especially under Gary Gensler, you have gone from a well-respected institution to one that is seen by increasing millions of Americans as a corrupt, out of touch organization that exists solely to protect the interests and wealth of insiders at the expense, and explicitly contrary to the wishes of, the individual investor." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289850.htm @ "It is complete [REDACTED] that you still have not approved the first BTC trust from Grayscale." (The same sequence of four letters was replaced by "[REDACTED]" when it occurred as part of the names of two other letler authors.) https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290920.htm @ "I also understand many politicians see Bitcoin as a threat to the dollar. Please allow me to assure you..." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290688.htm @ "Gary Gensler is effectively stealing $8 billion of investor capital by refusing to allow GBTC and ETHE to register as spot ETFs." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290462.htm @ "To whichever bureaucrat at the SEC is reading this: Please be a sport and approve GBTC as a spot BTC exchange-traded fund. [...] I'm a selfish investor who has a lot of money riding on this [...] but if you need another reason [...] the delay is an exercise in indolent absurdity" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290456.htm @ "I suspect that few or none of you actually understands Bitcoin" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290114.htm @ "Call it dummy insurance against government agencies getting everything wrong." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290186.htm @ "Bitcoin is the greatest financial asset ever created. It is fair, unlike the SEC. It is decentralized and distributed, unlike the SEC. It plays by a simple set of programmed rules, unlike the SEC." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-272921.htm @ "Hester Pierce conveyed the absurdity of the SEC's behavior on this matter best: 'I can't believe we're still talking about this as if, you know, we're waiting for one to happen,' Peirce said. 'We've issued a series of denials even recently, and those continue to use reasoning that I think was outdated at the time.'" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-273689.htm @ "The SEC doesn't want a spot ETF because it threatens them and the existing financial systems; their wealth and power. This is not about protecting American investors as much as it seems to be about protecting the wealth of you and your friends. Mark my words. [...] But previous [SEC] comments about not approving a spot ETF because it would cause the spot price of BTC to greatly increase is an act of manipulation in and of itself." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-278651.htm @ "Give the people what they want you fucking wankers!" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-279204.htm @ "Dear Chairman Gensler, Commissioner Lee, Commissioner Peirce (aka 'Crypto Mom'), Commissioner Crenshaw..." Hester Peirce often goes to bitcoin events and criticizes the SEC for not approving bitcoin ETFs. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-285077.htm @ "If GBTC is not given a spot ETF, I support that they go to court in a lawsuit." (Identical sentence in ) https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-285203.htm @ "If not approved, then wouldn't you be advocating a centrally manipulated tyrannical financial control system?" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290356.htm @ "I'm sorry, if you want to call me a conspiracy theorist go right ahead, but the only reason I can come divine for my country (the SEC) to deny Americans Spot ETFs has to be tied up with the culture of corruption in the US government." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290532.htm @ "And I do not expect true public honesty and transparency from an organ such as the SEC." The author signs "Peter Schiff" but does not specify profession or state of residence. The letter's contents is clearly taken from the Grayscale cover letter, only with superficially edited words, and the claim "Thank you for taking this time to read these comments, which are not simply copied into this email." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291472.htm @ "I own well over 3,000 shares of GBTC and I hold additional GBTC in my children's college fund. [...] I watched and took notes on every MIT class given by SEC Chair Gensler, 15.S12 Blockchain and Money, Fall 2018, all 23 videos and 29 hours, 15 minutes and 44seconds of it. He himself made the bold statement [...]" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291551.htm @ "It's obvious you guys approved the futures based bitcoin etf to facilitate price manipulation. [...] you're not a credible agency." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292476.htm @ "it is unfortunate that the SEC is seemingly doing everything it can to harm US investors rather than protect them -- I say that without exaggeration but backed by the data." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292383.htm @ "approve the GBTC spot etf..we want it and demand it NOW....i hope they sue your ass if not approved" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291606.htm @ "Please get out of the way and let the inevitable happen. If you don't, eventually more people will just start buying crypto directly and go around you, making you inconsequential and showing your lack of usefulness as an institution." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292300.htm @ "You DON'T know better." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291804.htm @ "We have a futures ETF so WHAT IS YOUR POBLEM?" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291873.htm @ "The SEC knows next to nothing about investing, hence your performance during Madoff. Not to mention naked short-selling, but you folks don't care about that, your lawyers! You just want to keep the current corrupt system and get a nice job in industry after your time at the SEC. How about doing something that actually helps investors before you leave the SEC? Your record of protecting investors sucks so far, so let's try something different. Go against your banker bosses. Approve a spot ETF." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292763.htm @ "Please stop breaking the law" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292108.htm @ "I am requesting you respond back to me within 2 weeks to explain why you are not protecting me." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-294692.htm @ "So again the SEC caters to the rich. [...] You guys are losing the public faith!" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-279133.htm @ "I was rather shocked to see the [discount] appear over the last year. GBTC has dramatically underperformed compared with Bitcoin. This seemed especially strange since GBTC was more expensive than Bitcoin for a few years. What changed? It turns out what changed is that the SEC has done something that surprised the market participants. The SEC has refused to allow a Bitcoin spot ETF!!" (Actually, the cause of the discount seems to have been the creation of spot ETFs in Canada and other countries, which took investors away from GBTC because of the 2% fee and lack of redemption. If the SEC had approved an ETF in the US, the GBTC discount would probably be much bigger.)

Letters making hyperbolic claims about Bitcoin

https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-297433.htm @ "Bitcoin is one of the top assets held in the world." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-268721.htm @ "bitcoin is futere [sic]" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269388.htm @ "Crypto currency's are the next big evolution in technology" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269582.htm @ "Bitcoin is the responsible response to the current macro-environment" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-268816.htm @ "Bitcoin is the scarcest commodity ever on this planet.." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269781.htm @ "Bitcoin is secure, open transparent and accountable. Perfect method of exchange" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270408.htm @ "that Idaho natives are leaving the metro areas and even the state because their dollar is worth less. Supporting bitcoin would help solve this problem." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270205.htm @ "Bitcoin promises to be fundamentally important to the future of global humanity" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269944.htm @ "some cryptos such as Bitcoin, as an non-inflationary asset, are as an excellent store of value" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270549.htm @ "Cryptocurrency has the potential to solve many of the world economic problems as well as upgrade the internet to handle forms of commerce beyond what has previously been thought possible." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270695.htm @ "Digital Assets are the biggest innovation since the invention of the internet." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270707.htm @ "Bitcoin is a faster alternative to gold such as Ukraine is using to keep their wealth. Bitcoin is a function(s) to help individuals navigate dangers." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-273134.htm @ By a "25 year old law student". Could be a good summary of all the lies that bitcoin promoters say. Or used to say -- now some of those lies are too obviously absurd even for them. "Like gold, it is scarce and finite and thus accrues value with ever-increasing demand. At the same time, it is easily transactable, like fiat currency, through the blockchain. It has done wonders for humanity [...] Blockchain technology is like the internet in the 90s. It is a revolutionary development in tech that will revolutionize the financial system as did the internet." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-273746.htm @ "[...] If [the US doesn't] approve Bitcoin, and high inflation comes in, U.S. citizens will become poorer. [...] Bitcoin can become a means of wealth storage like gold. Who owns the gold owns the wealth." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-279094.htm @ "The adoption rate has been the same as the internet. It's projected to be 1 billion users of Bitcoin in the next 5 years." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-279777.htm @ "BITCOIN IS pure genesis and fair genesis." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286320.htm @ "I believe the underlying cryptocurrency technologies are in line with other inventions such as the telephone and the internet, and that 100 years from now we will be taking for granted that everyone has equal access to a decentralized currency system" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291440.htm @ "I think bitcoin, being a decentralized, marginally uncorrelated, asset with large upside potential should be 1-3% of any responsible investors portfolio" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-294183.htm @ "Bitcoin is an incredible and important innovation -- possibly one of the most significant in human history." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269737.htm @ "Bitcoin offers an alternative infrastructure for the tracking of transactions, including those completed fraudulently, thereby enabling law enforcement to better accomplish their objectives of fighting fraud." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20116195-267877.htm @ "There's a growing body of evidence that bitcoin mining uses a higher mix of sustainable energy than any major country or industry, and can even stabilize the grid during peak needs (e.g. recent storm in Texas)." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-267791.htm @ "the ONLY ASSET IN THE WORLD that is not subject to debasement or manipulation by human hands" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-267300.htm @ "The rise of bitcoin from pennies to $69,000 is a direct reflection of the public's loss of purchasing power in the US dollar beginning in 1971 upon going off of the gold standard. Prior to March 2020 [...] had declined 86%. [... Bitcoin has] easy access for even the unbanked" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-296303.htm @ "Bitcoin is a messaging system at its core, and anything can be tokenized and represented on a digital asset Blockchain. Securities, Commodities, Currencies, Assets, Bonds, Identities, etc." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-296158.htm @ "I have not managed to save up enough yet for a home. [...] Bitcoin gives me a saving grace to this. Given that bitcoin is finite (only 21 million), and secure (backed by the most computing power in the world), I am confident in its ability to serve as a store of my wealth and be my saving grace in this trying time." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-296021.htm @ "There is no future economics without Bitcoin" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-295514.htm @ "Crypto is the Microsoft and Apple of this century!" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-294668.htm @ "I understand Visa and Mastercard provide [digital payments], but it does not provide the same sort of security digital currencies do. [... cards] are so easy to clone now adays with RFID readers. [...] China is banning world-wide cryptocurrencies as they want to develop their own" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-294424.htm @ "Bitcoin / Blockchain gave the world triple entry accounting. Bitcoin is the best global payment system and will be the best process for global settlement. Bitcoin is digital money and digital energy." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292925.htm @ "the freedom to move digital property by the fastest and cheapest means possible should be a human right." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292662.htm @ "Bitcoin truly has the power to change the world, and work towards fixing our broken monetary system." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292618.htm @ "BTC is the only hope honest people have left. This is a battle between good and evil." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292350.htm @ "Bitcoin is so hard to understand but if the brightest of our elected officials studied Bitcoin for 1000 - 5000 hours they would then reaalize and believe this will not only keep the US in the #1 spot worldwide along with it helping all other countries." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291521.htm @ "I've been invested in bitcoin miners since 2019. I have never sold a single share. To me bitcoin isn't risky, it's just volatile." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291514.htm @ "Blockchain [sic] used correctly is best for all. All. Not just some at the top ALL." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292199.htm @ "As an Environmental Biologist [...] I understand the thesis of Bitcoin Mining actually being the secret weapon to combating climate change by being a reliable customer of energy that will pay 3X what rate payers pay." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291494.htm @ "As time passes, the 'environmental' myth that Bitcoin mining is harmful becomes more and more debunked. Solar farms, flared natural gas facilities, Bitcoin mining companies' ability to stabilize the energy grid (preventing a blackout like what happened in Texas last year for example)" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291835.htm @ "Like the space race of the past, the digital asset race is going to sculpt the next few generations" (Maybe he meant "scalp" intead of "sculpt"?) https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292225.htm @ "Traditional Banks use more fossil fuels in buildings and operation than due cryto and blockchain technology. Bitcoin has demonstrated its strength for democracy and decentralized currency" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291624.htm @ "History has shown that every single government-controlled, fiat-based money system has screwed the citizenry [...] Bitcoin gives every person on earth an opportunity to trade freely with anyone else on earth. Just what god ordered." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289847.htm @ "Bitcoin is the only perfectly finite asset other than time" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289926.htm @ "I would argue Bitcoin is no less [sic] volatile than other stocks" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289722.htm @ "I at first was skeptical of Bitcoin and thought it was a danger to my investments and finance. That was before I actually spent the time to understand it. I really found that until I spent at least 10hrs of research, I had not really understood its fundamental efficacy in protecting wealth for my family and friends." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290135.htm @ "This will also strengthen the US dollar. Over 30% of all the Bitcoin produced worldwide is produced on American soil. When people demand Bitcoin, they demand US made products, services, and US dollars." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290151.htm @ "Bitcoin is misunderstood in many ways and is not a dollar replacement. It will be an invaluable tool to software developers in a way that fixes many aspects of the internet." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290226.htm @ "A survey by crypto trading platform Bitstamp shows that 80% of institutional investors believe crypto will overtake traditional investment vehicles. Some 70% of institutional investors said crypto was a trustworthy investment, with 68% actively recommending this asset class in investment strategies." Presumably that poll was taken among the institutional investors that are Bitstamp clients... https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290170.htm @ "I believe that it is a human right to be able to store the fruits of your labor, Bitcoin is the savings account that we all need." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291249.htm @ "I have almost 1000 hours of study into bitcoin and I have never come across anything as important and as SAFE as bitcoin is long term." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-272919.htm @ "I hope you do realize that Bitcoin can actually help reduce hyper-inflation currently in place now." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-279079.htm @ "Bitcoin could save the U.S. economy. Hear me out. The dollar's status as the world reserve currency [has] already reached the average end of life for a world reserve currency" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290962.htm @ "... I believe bitcoin mining is going to be a boom for renewable energies. The industrial miner's act like a battery on the grid...." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291568.htm @ "Bitcoin is the most important monetary innovation since the invention of paper money. [...] Bitcoin is not only completely harmless but beneficial to society in helping empower the unbanked and reverse climate change." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-279769.htm @ "There should be no conversation. It's revolutionary to our society."

Letters in favor from lawyers, companies, profs

https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20117343-268614.pdf @ By Dreyfuss Capital Management, in favor of the ETF but expressing vague concerns about manipulation etc. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20118548-271429.pdf @ By Coinbase trying to obfuscate, I mean, demonstrate that the Bitcoin market just cannot be manipulated; in fact "the Bitcoin spot market is comparably large and transparent compared to silver, palladium, and platinum markets, for which spot ETPs have been approved by the Commission" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20117566-270195.pdf @ From 'Founder, Discovery Capital Management' with usual arguments. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20122309-278362.pdf @ From 'Cumberland, a subsidiary of DRW Trading Group'. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20123653-279889.pdf @ From Virtu Financial. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20126838-287539.pdf @ From CEO of Elkhorn Consulting LLC with the standard arguments. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20127846-289065.pdf @ From the Security Traders Association. See also this other letter https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20126224-286791.pdf @ From the Security Traders Association. See also this other letter https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20116050-267770.pdf @ From a prof of EE-CS at Southern Methodist U., with graphs. Claims that bitcoin has stablized the Texas electric grid and is unlike other cryptos. Notes that of late it has been "highly corrleated with technology stocks" (actually r ~0.3 only) and that was the cause of the price drop. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20109603-263970.pdf @ From Coinbase. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20124021-280149.pdf @ From 'President and Chairman of BitGo Trust Company'. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20124102-280351.pdf @ From the Association for Digital Asset Markets (ADAM), whose members include Grayscale, FTX, Oasis, BitGo, etc. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-9411437-263052.pdf @ From the Blockchain Association. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20123987-280130.pdf @ From the Greyscale lawyers, arguing mainly that the SEC should approve their bitcon ETF because it has approved a bitcoin FUTURES ETF and the APA requires the SEC to be consistent. See also this letter. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-9410842-262990.pdf @ From the Greyscale lawyers. See also this letter. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20129971-296466.pdf @ From two staff of the NGO STand Together. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289052.htm @ From Donna Redel "Professor of Blockchain-Crypto at Fordham Law and a lecturer at Wharton", with footnotes even. "I teach in my courses a spot Bitcoin ETF is a far superior product than the one based on futures" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20120616-272805.pdf @ From Lightning Capital. Has a chart comparing the performance of BITO (the Bitcoin Futures ETF), GBTC at its market price, GBTC at BTC price, and BTC. Nothing surprising, but thought it may be useful. It includes a tweet from Gratscale promising to reduce the management fee and other advantages to investors if the ETF conversion is allowed. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20121464-273430.pdf @ From a 'Professor of Finance, Fuqua School of Business, Duke University'. With plenty of footnotes and detailed justifications. Tries to argue that the price would NOT be vulnerable to manipulation. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20128290-291006.pdf @ From a 'Retail Investor', with many footnotes. The author says "writing on behalf of Greyscale" but does not identify himself and the signature is illegible. The letter is dated "April 29, 2022" but the footer on every page says "November 29, 2021" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20123883-280057.pdf @ The author signs as 'Associate Professor of Finance, Georgetown University'. Blasts the SEC for not regulating many aspects of the crypto world: "* SEC must require entities engaged in crypto to have WSPs to avoid crypto from ransomware and other illegal activities. * The SEC has the legal authority to apply, and should apply, Regulation BI to all products, including crypto, carried by brokers and investment advisers, not just 'security' products. * Most cryptos really are securities, and the SEC should quickly but gently bring them into the regulated world with a principles-based sandbox approach, not regulation by enforcement [!?!?]. * The SEC should adopt a Rule 15c2-11 approach to brokers trafficking in cryptos * It is in the public interest to require entities engaged in crypto to disclose their environmental impact" But then concludes of the ETF... https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20129977-296478.pdf @ Repeats the arguments of the Greyscale template. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20128711-294120.pdf @ Has the Grayscale letterhead but the text is a copy of the comment template, and it is signed by "Patricia Worth" with no job title or further identification, with a placeholder "[DATE]" in place of the date. Could it be that the author copied and edited the PDF of the message he received from Grayscale, instead of copying just the comment template? https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20130009-296497.pdf @ From a Professor of Finance at Vanderbilt University, with several charts and tables. Has a detailed analysis of the performance of the BITO futures fund. However, the very attempt to compare BITO to the proposed ETF indicates that he has not fully grasped the fundamental difference between the two (or is consciously trying to obfuscate it). https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20118613-271492.pdf @ No peron name. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20126500-287142.pdf @ From Fortress. They have a "crypto" division. But they call "GBTC", confusingly, just "BTC". The letter explains the SEC's explanation of why it approved a BTC Futures ETF but has denied all BTC spot ETFS. Namely, the SEC had previousy decided that any Futures ETFs would be approved without examination. Fortress then argues that the SEC should be consistent in its mistakes. Fortress also argues that BTC is not prone to manipulation because it "has strong links to a regulated market of significant size (i.e., the CME)". But that does not make sense to me bcause the Chigago Mercantile Exchange is where BTC Futures are traded, not BTC itself. Right? And of course no mention of BTC manipulation through vapor-backed USDT. On the contrary, they claims that manipulation of BTC price would be "terribly expensive". That is flatly dishonest... https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20127445-288569.pdf @ From director of the "Peter J. Werth Institute for Entrepreneurship and Innovation" at the University of Connecticut. According to the Institute's page "David is an active mentor at UConn, and has recently founded Zatoichi Co., a blockchain based startup. Prior to UConn, David was a securities and corporate finance attorney" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20127753-288947.pdf @ From "Professor Carol R. Goforth, a University Professor and the Clayton N. Little Professor of Law at the University of Arkansas (Fayetteville) School of Law" is clearly cribbed, footnotes and all, from that of Prof. Donna Redell, as well as from the "Last October..." spam template. She claims to have no investment or any vested interest in GBTC whatsoever, and is supporting the conversion to ETF only because the "arbitrary and capricious" attitude of the SEC "might lead to wasteful litigation". I can't imagine a lawyer seeing this as a BAD thing....

Other notable letters

https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-299570.htm @ "I have learned many hard and embarrassing lessons through cryptocurrency, but ultimately I believe that it should be accessible to as many people as possible" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-273680.htm @ "I need to see my Grayscale Bitcoin Trust GBTC pop in the aftermath of the SEC acceptance of their BTC ETF application" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-296759.htm @ "Please allow for many spot Bitcoin ETFs from reputable & auditable custodians." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-295921.htm @ "Please make GBTC part of the FEC [sic] and stay out of the road" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-268867.htm @ "THIS TRUST SHOULD NOT BE TREATED ANY DIFFERENTLY THAN ANY OTHER." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269569.htm @ "As you all know, the new generation is fed up with the futures ETF and want a fair spot ETF." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20117483-269652.htm @ "It is sad that these comments are futile. It is sad that only the worst of us run for office. Maybe it's the 2 party system. Maybe it's the media left and right." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-268961.htm @ "Due to COVID-19 business impact, I was released from Medtronic. Out of necessity to support my family during this challenging time, I will be forced to liquidate a % of position [...] Selling down GBTC holdings at a (-25%) discount to NAV has severely limited accessible financial resources and attributed [sic] to mental health concerns" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20115439-267489.htm @ A letter in -- by The Savior himself...? Gives the affiliation as 'Blockchain'. Sure... https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20117568-270196.pdf @ This letter (by The Savior himself?!? Sure...) mockingly 'thanks' the SEC because, with its repeated refusals to allow a Bitcoin ETF, starting with the Winklevoss attempts, it spurred progress of Web3 infrastruscture in many ways, such as the growth and public listing of Coinbase and the creation of FTX. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269642.htm @ "As a holder of Bitcoin, GBTC and ETHE, I fully support that both of these be converted to spot ETF's." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-268808.htm @ "I cannot understand why this conversation [sic] has not been approved." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269436.htm @ "BTC spot ETF now! WTF Gary? LFG!" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270373.htm @ "Please do the wright [sic] thing and let it pass... [sic]" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270300.htm @ "Please also encourage those you know to end the mandates." (?) https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270233.htm @ "Check out what JNUG did in the three week period from February 22 thru March 14, 2020." (It crashed from $950 to $33. That would be a good argument to avois ETFs...) https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270200.htm @ "Other contraries [sic] have unrolled their own ETFs without issue." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270235.htm @ "And while you're at it, drop that ridiculous Ripple lawsuit. You never gave them adequate legal notice." (But a lawsuit is the way to serve a legal notice...) https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269917.htm @ "As both an investor and the co-founder of a robo-advisory platform in the United Arab Emirates, we thank you for considering the conversion of GBTC to an ETF. We use it as part of a 5% exposure to bitcoin and the reception has been phenomenal" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270412.htm @ "How can you allow for a MARIJUANA ETF when Marijuana is literally illegal. But no spot Bitcoin ETF. Huh? SEC, This is unacceptable. Let's get it done SEC. You got to pump it up! Don't you know pump it up! You got to pump it up! Don't you know pump it up! You got to pump it up! Don't you know pump it up! Sincerely, [...]" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20117627-270318.htm @ "I like three things: Hookers, ETFs, Crypto Currency. Give me two at once and Ill die happy." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270361.htm @ This letter is supposed to be, but lists several flaws and risks of GBTC and says that converting it to an ETF would soulve only a couple of them. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270766.htm @ "If American adults can buy lottery tickets, they should be able to invest in a spot Bitcoin ETF." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270728.htm @ "The fact that their parent company Digital Currency Group owns Foundry, a bitcoin mining operation, allows them to continually mine bitcoin as the trust grows in order to maintain a physically backed ETF product (in an effort to avoid market manipulation)" (But the proceeds of the Foundry mine do not go to the GBTC fund or to the proposed ETF, and in fact -- like all mining -- is a force pulling the BTC price down...) https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270687.htm @ "The birth of the second roaring twenties, please Madame Secretary Countryman, allow me to invest in an product such as this ETF" (I suppose he does not know what happened in the first 'roaring twenties', that motivated the creation of the SEC...) https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-270883.htm @ "please allow Grayscale to convert it's Trust products into spot ETFS. for GBTC, ETHE, ETCG and their trusts." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271073.htm @ "PS: please do something about SPACs and IPOs. They are not transparent enough." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271785.htm @ "I have given more than 50 television, newspaper, radio, and magazine interviews since 2017 regarding bitcoin." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271961.htm @ "I support converting Grayscale's Bitcoin and Ethereum closed-end funds into spot price ETFs" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20119862-272653.htm @ "myself and clearly many other investors have been anticipating approval of GBTC conversion to a spot ETF" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-272622.htm @ "I am representing approximately thirty-five close family and friends in this matter. [...] As divided as our country is politically, the bipartisan Congressional Blockchain Caucus is advocating for the same product [...] I hope you have a splendid St. Patrick's Day." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-278533.htm @ "Please post this on webpage. I have sent in 3 submissions and I see none posted." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-273015.htm @ "[Greyscale] have promised to lower the expense ratio on the product 'GBTC' from 2% annually to an unspecified number." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-273118.htm @ "Please consider approving this and ALL Bitcoin Spot ETFs!" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-273397.htm @ Letter in Spanish. Translating: "[...] It is not the SEC's job to control the market, only to ensure that it is truly a free and transparent market" But 'free market' does not mean 'free from government regulations'... https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-273453.htm @ "Hi there pleasure to hear from you and truely glad to be here finally some enlightenment as I come forward and make full circle of my life and secure my holdings to be righteously given to me after all this time I have waited and wondered questioning my own existence as a one individual body and person alive and well for now. However during my upbringing I have encountered many hardships, struggles and many discomforting situations unknowingly brushing with life itself [...] I am much wiser than I make look or even know about myself not getting confused with reality and dreams, past now present in time and space in this world today. I hope to hear from you so we can discuss much more greater views and share knowledge and wisdom and possible business opportunities." And does not even mention the GBTC or the ETF. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-273424.htm @ "GPS took 25 Years for OUR Government to fund!" Actually it took 13.787±0.020 billion years. But eventually GPS was invented, developed, funded, and operated entirely by the US government. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-273413.htm @ "The current situation is very damaging to investors because the trust fees are 2% [...] Bitcoin is up 5% one day, while GBTC is up 1% ; Bitcoin is down 2% one day, while GBTC is down 4 %" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-273389.htm @ "Futures are games players 24/7 by algorithms and well capitalized companies funding this trading." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-275478.htm @ "[The BITO futures ETF] is not appropriate for long term investors because of mechanisms, such as con tango [sic], that guarantee a loss to long term holders" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-275464.htm @ "Approval will also allow for future conversion of the Grayscale Litecoin Trust (Symbol: LTCN)" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-278320.htm @ "There is no more risk than with microcap equities" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-278594.htm @ "I have acount with grayscale.i would like to in vest in Grayscale's.what is my balance at the moment. PAUL.. I HAVE WALLETS WITH AAX .I WAS IN GREYSCALË AT ZONE ACCOUNT 19978286.I SEEN A FIGURE OFF $ 457.18 B." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-278724.htm @ "[A bitcoin ETF] is a theta neutral, long volatility vehicle that is much needed" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-278708.htm @ "The United States was founded on the basis of certain unalienable rights, amongst them life, liberty and the pursuit of happiness. Approving Bitcoin Future ETFs, but not Bitcoin Index ETFs, is a denial of Liberty and the pursuit of happiness." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-272569.htm @ "I admit I did not fully understand the premium/discount inbalance inherently possible with the Trust, thinking it should act more or less like an ETF" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-279054.htm @ "I'm down 20% just because of the discount. I wasn't counting on this when I invested thinking Grayscale #GBTC was going to mirror the spot price of BTC! It's been a devastating journey for my IRA since then!" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-279841.htm @ "Approval will also allow for future conversion of the Grayscale Litecoin Trust (Symbol: LTCN), currently the world's largest Litecoin fund, to the first Spot Litecoin ETF in the United States" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-279797.htm @ "Convert GBTC already!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286232.htm @ "I want the SEC to allow Grayscale to convert GBTC to a spot ETF. I thought it was one when I originally bought GBTC." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286042.htm @ "I hold both GBTC and MSTR in order to make an investment allocation in Bitcoin." (MSTR is MicroStrategy, a software firm that turned itself into a Bitcoin fund, bypassing the SEC.) https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286192.htm @ "I purchased GBTC years ago [...] I was upset that I had to buy the fund at a premium to NAV due to the fact it was not an ETF, but I made the purchase anyway because I thought it was still a compelling investment. Now I am faced with a discount to NAV and although the price has gone up I have suffered significant losses" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-285683.htm @ "Please send me the link to submit an online comment re: SR-NYSEArca-2021-90" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286288.htm @ "Hello, I currently hold a long position in GBTC and received notice that my input was necessary ref." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286604.htm @ "Just leave Elon alone and convert GBTC into an ETF already!" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286489.htm @ "Money. That's why." (That is the whole letter. Is it in favor or against?) https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-288961.htm @ "I am not attaching some form letter to my request." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-294735.htm @ "Please approve GBTC Spot Bitcoin ETF. If not, then please cancel all future Bitcoin ETFs that you have already approved." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271868.htm @ "How is it that Canada, as a socialist country masquerading as a Democracy, is affording more choice to its citizens than is the United States" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-285010.htm @ This seems to be the first letter to use the template supplied by Grayscale on 2022-04-22, that contains the paragraph "Last October, you approved futures-backed Bitcoin ETFs, but continue to reject[...]" More than 800 comments were received on that day. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-268723.htm @ This seems to be the first letter to use the template supplied by Grayscale on 2022-02-22 that says "I'm writing to support the conversion of Grayscale Bitcoin Trust (Symbol: GBTC), currently the world's largest Bitcoin fund [...]" Thousands (literally) more followed. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269198.htm @ "If [the ETF can't be approved] please force Grayscale to close their trusts, sell the underlying assets and pay out their share holders for the NAV per share." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269789.htm @ "As an investor in BTC who has lost the private keys to his Bitcoin" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269690.htm @ This letter from 'Crypto Gold' is signed twice as 'Wayne Perser' and 'Wayne Purser, Director' https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-269732.htm @ "I have been an investor in GBTC for quite some time as well as gotten my parents invested in Bitcoin through GBTC." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20117291-268506.htm @ "If [you don't approve the ETF] then you should rescind the ETF status of all the other incredibly volatile ETFs that you gave ETF status to no problem. Eg: ARKK, TQQQ, SQQQ, UVXY, etc etc etc....." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-268543.htm @ "some listed companies have already decided to go for the 'Bitcoin on the balance sheet' approach" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20117266-268481.htm @ "I write a column for the financial markets website Seeking Alpha, and my readers and I are eagerly watching the developments of this case" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-267946.htm @ "I bought this before all the hedge funds we're buying this to get exposure to btc when it was trading close to NAV. Now they left and Im bag holding paying a 2% management fee and trading at a 27% discount to the underlying assets." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20116295-267934.htm @ "what level of majority [in the pro vs. con comments] is required to persuade SEC to change it's policy?" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20116080-267803.htm @ "If people can buy properties as store of value for their money, why not bitcoin. The house need upkeep, it affects the environment as well. [...] Energy is going to be abundant and clean with fusion." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-294765.pdf @ "I will be 90 next year. The quickest way to get much older is Waiting for something to happen. Anyway 😕" See this other letter https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20116178-267851.htm @ "Quickest way to get old in Waiting. Soon I will be 90 years old." (That is the whole letter.) See this other letter https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-267738.htm @ "I have family abroad in Brazil that are doing all they can to buy as much as they can given the value of fiat currency." Yeah, sure... https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20116059-267779.htm @ "there are a lot of bad actors who do not pay crypo taxes using offshore exchanges. Buying GBTC through US brokerages ensures taxes are reported and paid" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20116040-267758.htm @ The author signs as '(Elected) Escondido City Treasurer; Wealth Manager, Yorkshire Wealth Management'. Claims that the conversion is supported by "many other elected officials and wealth managers". https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271875.htm @ "You can start with GBTC and then extend this to all others who filed for a Bitcoin spot ETF." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20115468-267511.htm @ "Many retail investors like me bought GBTC with insufficient knowledge of how a closed end fund functions, and wrongly assumed that the price of GBTC would follow the underlying asset." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-266140.htm @ Claims that since the proposed spot ETF would trade only during normal trading hours, it would be less susceptible to manipulation than Bitcoin itself. Does not make sense, right? https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-261928.htm @ "and do not allow other bitcoin spot ETFs to begin trading before GBTC to protect the 40 billion in AUM from further harm" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-261151.htm @ One of the first comments received by the SEC. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20115444-267494.htm @ The author of this letter in favor gives his affiliation as "CEO of the FED printing press" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-296125.htm @ "Let my people go. All [sic] the conversion of the GBTC to an ETF." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-296150.htm @ "I am State Representative Joel Bomgar. I serve in the Mississippi House of Representatives in Mississippi and I am in favor of [the ETF]" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-295913.htm @ "I am sinlam, NFT collector from Hong Kong" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-294657.htm @ "It is currently very hard for investors to allocate and DCA [invest by dollar-cost average] a portion of their investments to something such as Bitcoin. I have personally mistyped addresses and paid outrageous fees to hold crypto." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-293921.htm @ "Currently the Main Stream Media see's [sic] no difference between 'Tech Stocks,' 'Crypto Currencies' and 'Bitcoin.' [...] However, there is a MASSIVE DIFFERENCE between these three things. [So approve the ETF]" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-293950.htm @ "I am a GBTC shareholder and Lost a lot of money already" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292583.htm @ "I am a conservative investor and do not venture beyond bitcoin in the crypto space." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292562.htm @ "The SEC governance and oversight [...] is exactly what is driving people away from institutions and into DeFi; and [...] just drives hatred for the wealthy who have access to even riskier investments because...they're more sophisticated? Really, I know so many people that are accredited investors, and they know nothing." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292158.htm @ "investors in the USA are the most savvy in the world." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292724.htm @ "I been dealing with Coinbase they're crooks money missing they say they're not responsible how could it possibly be !" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291837.htm @ "It is my sincere hope that this email doesn't go into digital oblivion" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291672.htm @ "Bitcoin can save our economy! But you don't see it because of old ways that have worked in the past. Bitcoin is the way to give poor people money without printing more. Bitcoin is the stimulus the people need. When Bitcoin rises so does all the coins poor people have. When poor people (all) make extra money they spend it on necessities and things they want. If they make enough they buy cars, homes, etc.. We want a Bitcoin Spot ETF. Because it will raise Bitcoin and ALT. coins." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292183.htm @ "With Trillion Dollar companies like Fidelity lobbying for an ETF as well, I don't understand why this has not been approved after all these years." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291523.htm @ "You guys are amazing truly are and we all our [sic] human. All things phase out over time. Let beauty reign. In the heart one knows what is true." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292289.htm @ "This is the UNITED STATES OF AMERICA, if the people will it, then that's should be." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292200.htm @ "I am turning 60 years old in October [...] I educate Gen X and Baby Boomers about digitalization, and many say that they would like to invest in these exciting technologies and want to keep these brilliant computer scientists, coders, and innovators in the U.S." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292176.htm @ "[I] and have lived in several states and have been to many other countries throughout the world. When I visit abroad I think about the freedoms that the citizens of those countries have compared to ours. One of these freedoms that other countries enjoy is the ability to invest in crypto more freely than US citizens." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291769.htm @ "I think the government protecting me from my own investment decisions while at the same time allowing me to piss it all away at a casino in Vegas is ridiculous." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292336.htm @ "I am [...] a stock market trader graduated from the Viña del Mar University of Chile, the first generation of Latin American cryptocurrency traders". Gives some TA mumbo-jumbo that is supposed to show that Bitcoin is the new gold. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291850.htm @ "Netflix dropped from $700 to $175 in 4 months. Bitcoin preformed [sic] better over the same time period." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292254.htm @ "Approving futures based ETF which you have already done and not a SPOT product like GBTC is the same as making porn legal while at the same time making the actual fucking illegal. Make it all legal." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291561.htm @ "I moved to Texas so that I could have just a marginal increase in my freedom of choices. [...] We have our own energy grid that has amazing benefits in flexibility and competition. One week it failed spectacularly, and yet most of us stayed the course anyway." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292207.htm @ "why can I collateralize my house and throw the proceeds in some obscure derivatives market, but I don't have the option to buy a simple product like a bitcoin spot ETF with some excess cash?" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291787.htm @ "My 401k performance is as follows: AAPL: -13% [...] PYPL: -59% NFLX: -71% [...] i want the same ability to choose to invest in a gbtc converted spot Bitcoin fund" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292018.htm @ "This will help my family overcome poverty [...] We survived the COVID-19 lock-downs, unemployment, forbearance mortgage payments, but inflation we may not survive. Our family is begging you. Our lives are in your hands, literally. Sincerely yours, Hard working blue collar family man." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291649.htm @ "There are a lot of shady securities out there and a lot of shady folks cheating to trade them. What do those securities have that Bitcoin doesn't? [...] I want to own a piece of that in my IRA." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289118.htm @ "... I recently invested in a BTC IRA via Gemini and IRA Financial Trust, only to have my account hacked and my BTC stolen. A BTC ETF run by Grayscale would provide the protection and security ..." Does this "hacked and lost" claim make sense? https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20115436-267471.htm @ "I need gbtc to be an etf bc I invested my life savings into it. I need it to be actual btc price. To me it is like gold. I invested my familys money as well. I want fairness. I am managing over 5 mil as retail investor. am tierd of Sec [sic] protecting people. You just want to help the rich and give them access first. Please listen to the retail persons and make gbtc pegged to real btc." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289875.htm @ Badly formatted letter. The "From:" field says John Ellsworth but the lettes is signed Judy Ellsworth. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290018.htm @ "I own close to 7,000 shares of Grayscale [worth now ~10 million USD], and I also own Bitcoin. Grayscale is a large portion of my retirement account." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289530.htm @ "I own 1,000 shares of GBTC [worth now ~1.5 million USD]" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289923.htm @ "you are not protecting me, the investor from the very person you were appointed to protect" The "from" was a "---" in the Grayscale template. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289961.htm @ "(I am not going to copy this whole letter)" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290557.htm @ "I, a sovereign individual, would like to invest in an asset called Bitcoin." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290672.htm @ "I have an engineering degree and two Master's degree [sic], including an MBA. I fully understand the risks and rewards of owning and trading crypto currency, NFT's, stocks, bonds, mutual funds, ETFs, 3x leveraged ETFs, commodities, precious metals, and real estate. I win, lose, succeed, and fail on my own, with my own decisions. I do not need or want 'big brother' SEC or federal government telling me what I can and can't do with MY MONEY!" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289939.htm @ "holding a small amount of BTC has been shown to offset portfolio volatility which is why many experts" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290615.htm @ "I own six figures of GBTC and other Grayscale funds and seven figures of crypto." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290519.htm @ "From: Shonntte Baldwin ... I'm writing from Shonntte Baldwin, with gratitude" The Grayscale template said "I'm writing from ***[ ADD YOUR STATE HERE ]***, with gratitude". https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289770.htm @ "[Because of the 25% discount] shareholders like me are experiencing a destruction of value of around $7.5 billion. Personally for me it is in excess of $100,000." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290427.htm @ "it's great to be buying bitcoin at a discounted price but I would rather buy and sell at the market price." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290235.htm @ "I would like to buy a spot etf and own bitcoin as a security rather than property because big brokerage firms allow easy borrowing against securities and they don't currently allow borrowing against bitcoin (as property). Schwab is one example." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20118386-271293.htm @ Anyone remembers the "Twinkies defense"? Meet the "Oreos defense": "I like Oreo cookies. They arent good for me but I like them, I buy them and then I eat them. Garry Ganslery doesnt tell me that I cant eat Oreos. So why cant I buy bitcoin even if its not good for me? Let me eat my Oreos." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20120801-272969.pdf @ This guy is in favor of converting GBTC to an ETF, but he is actually invested in ETHE, Grayscale's Ethereum fund. He notes two interesting points (1) if GBTC becomes and ETF, he hopes that ETHE will become one too; however (2) he lives in the EU, and while he can own ETHE, he would not be allowed to own the corresponding ETF, and so would be forced to sell the ETHE, at a loss and against his will. I wonder how many GBTC investors, especially those who spammed the SEC, live outside the US and are aware of (2)? https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20123627-279874.pdf @ In favor, but is more interested in Greyscale's Ethereum fund ETHE being converted to ETF. However, claims that, as a US citizen resident in the EU, he will not be able to invest in the ETF. Is this correct? https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-20128859-294702.pdf @ Does not ask for the conversion specifically, but only generically for the SEC to provide some way to equalize the GBTC NAV to the spot price. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271275.htm @ The usual "It would be good for me" blurb, then one page of disclaimers, including an ad for his accounting company. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271353.htm @ "Greyscale knows what they're doing. Bitcoin knows what they're doing. I want it. That simple." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271974.htm @ This one is half conscious: "Dear SEC, Buying other currencies and commodities as ETFs is a convenient gamble, so why not allow people to gamble with bitcoin?" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271975.pdf @ This letter quotes a 2022 text by Joseph Grundfest, former SEC commissioner. Joseph basically says (not with these words): "It is true that the BTC price is manipulated and the markets are dirty. But then the Futures ETF BITO should have been rejected too. Since the SEC blundered and approved BITO, the SEC must approve the spot ETF too. Because being consistent is much more important than doing the right thing." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-272107.htm @ "I am a bedside nurse in Dallas, Texas, and have been fascinated with blockchain technology for several years." Unfortunately he/she has not had the time to master more promising technologies, such as microsample blood analysis, compact tokamaks, or wormhole navigation. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-272498.htm @ "I bought GBTC for my Roth IRA because my broker Schwab does not offer direct bitcoin investments." This guy suggests that the SEC, instead of converting GBTC to an ETF, should order Grayscale to let shareholders to redeem their shares for the underlying BTC. Which presumably would mean the liquidation of GBTC, given the current negative premium. Right? https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-272737.htm @ In favor but complains about the index including OKCoin's price. Wants it to be replaced by Kraken's. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-273056.htm @ "Even Brazil has a spot ETF" Shame on us down here. As if COVID was not enough... https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-273091.htm @ "Borrowing from Ryan Selkis, CEO and founder of Messari. 'A normal ETF ...'" Wasn't Ryan's alias "Two-bit Idiot", years ago? https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-273330.htm @ "I am aware of Chairman Gensler's concerns that Bitcoin is the 'wild west.' But remember that the wild west was tamed only by allowing people to own it outright. Likewise, BTC spot ownership is outright ownership" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-278723.htm @ "I have invested in multiple Grayscale Trusts continuously for the last three years. Grayscale has always communicated its intent to convert to an ETF, and I made my purchase decision knowing this was always the ultimate path. Please approve or provide a pathway for conversion." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-278732.htm @ Claims to "love [sic] in California and teach Business at Stanford University". But he is actually a "consulting professor", which does not seem to imply any teaching roles... https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-278743.htm @ Edited the "***[PLEASE WRITE YOUR THOUGHTS IN HERE...]***" but left the "***[" and "]***". https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-279967.htm @ Says that he and his family invested in GBTC and lost 11% so far while BTC itself gained 21%. He does seem to be asking for GBTC to be made into an ETF, but wants the SEC to approve an ETF that tracks the spot price of bitcoin. Is GBTC going to magically do that, if it becomes an ETF? https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-285033.htm @ Waxes philosophical: "Accounting and financial performance measures are practically illusions covering the true human dynamic at play that affects almost all returns." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-285145.htm @ "From New Jersey". Says "Because Chairman Gensler must be in the pocket of the banking industry [...] Gensler has not put a wash rule in place for Crypto, which causes the price of Bitcoin and other Cryptos to fluctuate wildly from traders playing games. The only reason why Gensler would not implement a wash sale rule for Bitcoin is to keep the price volatile, much to the delight of his buddies in the banking industry." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-285155.htm @ Some ancient Chinese wisdom by Chi Shing Siu from Hong Kong: "Human's desire is like energy, it will flow like water, same as money, it will flow to where it wants to go to or tends to go to, if you try to stop them here, they will flow to other places to continue the trend, it is unstoppable." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-285538.htm @ "when I purchased gbtc as not aware that it is not already an etf and filing taxes this year has been a giant hassle". Which shows how well informed the GBTC investors have been... https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-285889.htm @ "I understand that the US has a considerable vested interest in keeping the dollar as the world's reserve currency, but I do not believe that approving a spot ETF for BTC in anyway threatens the dollars dominance." Ah well, then, ... https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286170.htm @ Should this letter be counted as being in favor? "[I] have no idea why I am [writing] this because my investment in GBTC is shit. Bitcoin should be called 'Shitcoin,' [...] if you support of the conversion [...] please be sure to consider the poor shmuicks like me who put money into this stupid fund. Id like to know for sure if being an ETF will really work. I just wish I hadn't bought into Grayscale SHITCOIN Trust." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286278.htm @ This letter mentions that "10 to 15 years ago" it was possible to buy bitcoins with the "smile points" offered by a long distance phone carrier in California, which has since stopped serving the state. Does anyone know about that? https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286442.htm @ An interesting argument in favor: "The current BTC futures price ETF is an abomination and only serves its Wall Street masters so they can manipulate the spot price at the expense of the retail investor you are supposed to be representing and protecting. A spot price BTC etf product would level the playing field and give retail and institutional investors equal access to Bitcoin" Is he saying "We want to manipulate the price too!"?? https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286636.htm @ This letter notes "Vanguard is doing away with GBTC because it is OTC and will remove access. Schwab and TD Ameritrade charge for trades on it because it is OTC." 🤔 https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-287027.htm @ On April 22 there were 52 letters by "Anonymous". In this one, the guy asks the SEC "please keep me anonymous". The SEC did indeed list his name as "Anonymous" on the list of letters. But kept the "From" field with his full name. 😄 https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-288765.htm @ "Be assured, my motivation is to remove all incumbents as the are mostly crooks." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-288936.htm @ Here is an original "computational" argument in favor of the ETF: "I invest money for a family office [...] I use GBTC [...] for diversification. I have algorithms which readily rebalance based on set correlation goals between anticipated price movements of portfolio assets [...] GBTC's behavior as a trust undermines my goal, as its erratic relationship to the spot price of bitcoin makes it harder to optimize position size." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289491.htm @ "Vanguard just restricted trading of OTC products, so now I can't buy more until GBTC is made an ETF." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289508.htm @ "as an active retiree I manage our savings with my wife. We invest in ETF's as a way to balance our risk and converting GBTC into an ETF would support our conservative strategy to grow our savings in the long-term as opposed to an speculative strategy." Besides the Grayscale letter template, it includes part of Grayscale's cover letter from Grayscale suggesting that shareholders write to the SEC. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289631.htm @ "My only concern is that in the conversion process that the original value (correlation) between the USD I put in vs BTC's value at that time will be accurately reflected in the conversion... regardless of today's BTC value." One of the guys who bought at $69k, and wants that money back? https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289675.htm @ "I write to you as a SUFFERING GBTC shareholder" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-289749.htm @ "As a brazilian and shareholder of GBTC it reaaly suprise me why SEC has not approved GBTC convert to ETF." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290012.htm @ Very long letter with bits of the Grayscale template interspersed with a rambling account of the tragic but quite irrelevant history of how his once wealthy family that "built Ruddell's Fort in December 1779", owned a hospital in Indianapolis, and founded a $120 million charity, was scammed out of their 100s of millions fortune by dishonest lawyers and now he is a small investor who invested in GBTC and all other Greyscale funds. He says "instead of building a hospital my family should have invested in mining bitcoin". Praises not only GBTC but also BCHG, Grayscales Bitcoin Cash (BCH) fund. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290198.htm @ "contact me if I can be of additional assistance" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-292370.htm @ "I am Amir Eliav, 33 years old, [...] a real estate investor and a realtor [...] am i going to grow my business 8% YoY just to keep up with inflation? [...] Bitcoin is my savings account, Bitcoin is my real estate, Bitcoin is my retirement. Bitcoin is hope for me." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290965.htm @ "Hi SEC comments: I am an owner of GBTC shares in both Etrade and TD Ameritrade, for both taxable and retirement (roth, normal Ira) accounts. I bought GBTC (and the Ethereum Grayscale equivalent) ... I now realize that I have purchased a faulty financial product [... so please fix my mistake]" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291002.htm @ ""Crypto is the future. Tell that fossilised, one trick pony WARREN BUFFET, he doesn't know his arse from his elbow!!" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-291023.htm @ "I am Adam Beiter,36, a construction worker, cook, and crypto/stock investor." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-294096.htm @ "the SEC is dragging its heals [sic] in approving GBTC's conversion to an ETF." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-294975.htm @ "Pls sec help us to resolve this issue bcus here in Nigeria we depend much lot on crypto bcus their is no sure Of living in the country" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-279296.htm @ Letter in Spanish. Translated: "I am from Mexico City, Mexico State, Metepec County. My investment was supposedly made with you [?!], with some HarrisGray Trader BTC, who explained how the investment worked and effectively made it since April 2nd of this year for the amount of 100 dollars. Later he told me that it already had made a profit and asked me 800 dollars more to pay the 'tax bot' tax, has been pressuring me to get it and in the end I paid but he did not answer." ('Tax Bot' seems to be a popular tax preparation/management app in Mexico.) https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-273817.htm @ "Good evening commissioner, How is your day going? I am Ku from South Korea" But the 'From' field says 'Drawtech Swag'. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271714.htm @ "P.S. while you're at it, get rid of accreditation laws. They, too, only serve to deny access to the less-wealthy while divvying up their piece of the pie among the wealthy." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271553.htm @ "Prior to 2021, I was not a believer in crypto generally, largely due to a lack of research and understanding." That was indeed a 'great' moment to get in 🤦... https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-299946.htm @ "I wish to invest on do state [sic]" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-299952.htm @ "Dear SEC, vB Vy , n n cn j akibatjih adipisicing 6jn b8 Bi7. B tcoin josh k [sic] Sincerely" (Comment sent by a cat walking on keyboard?)

Spurious stuff from fat-fingered copy-paste

https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271373.htm @ "AMFM One Nation Under God Oneluv17" https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271985.htm @ "Mario 11:15 AM Thanks @Binna (she/her). In the process of making the changes." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-272157.htm @ "Mario 11:15 AM Thanks @Binna (she/her). In the process of making the changes." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-272581.htm @ "Mario 11:15 AM Thanks @Binna (she/her). In the process of making the changes." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-278823.htm @ "I want to request an Ownership Account please. My real name should be as the account holder." https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-279731.htm @ "CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe." Many other letters have this text at the top. I don't know whether it was in the Grayscale-suplied template, or was added by the sender's or the SEC's mail reading app.

Broken links on the SEC comment list

https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-299559.htm @ Letter is completely blank due to SEC HTML markup error. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-297097.htm @ Letter is completely blank due to SEC HTML markup error. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271771.htm @ 404. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271772.htm @ 404. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271828.htm @ 404. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271829.htm @ 404.

Duplicated entries on the SEC comment list

https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271770.htm @ Duplicated. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271879.htm @ Duplicated. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271880.htm @ Duplicated. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-271881.htm @ Duplicated. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-285697.htm @ Duplicated. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-285701.htm @ Duplicated. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-285793.htm @ Duplicated. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-286107.htm @ Duplicated. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-290014.htm @ Duplicated. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-293994.htm @ Duplicated. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-294958.htm @ Duplicated. https://www.sec.gov/comments/sr-nysearca-2021-90/srnysearca202190-294967.htm @ Duplicated.

Last edited on 2022-06-16 08:50:24 by stolfi