Thanks for the explanation, if this is the case then the SEC policy doesn't seem to make a lot of sense.
After accredited investors purchase shares and hold for 1-year, they are now selling those shares to non-accredited investors on the OTC market. Which means that non-accredited investors are buying the fund in the end. The only difference for GBTC is that only accredited investors can initiate the creation of shares, but anyone can trade them.
If I'm understanding this correctly is seems absurd.
The "Accredited Investor" thing was relevant until last October or so, while BIT was under different rules. Accredited Investors (i.e. individuals with "money that they could afford to lose") could buy shares directly from SecondMarket by paying in USD, at about the current price o 0.1 BTC per share.
Now, only "Authorized Pariticpants" can get shares from Grayscale, by giving BTC to it. SecondMarket is an Authorized Participant and so they may still be able to act as middlemen and sell new shares to individuals for USD, as they did before (does the 1 year holding apply to them too?). If so, perhaps they still require the buyer to be an Accredited Investor. Those shares would still have to be held for one year before resale. Perhaps SecondMarket now can charge a premium for those shares?
Qualified accredited investors** can choose to invest directly in the BIT at the applicable NAV per share. The BITs shares are subject to significant resale and transfer restrictions.