Subject: File No. SR-NYSEArca-2021-90
From: Richard Craig Vasquez
Affiliation: Attorney at Law

February 11, 2022

The US is falling behind digital asset innovation and investment by failing to approve a spot bitcoin ETF. Limiting ETF investors, who desire exposure to Bitcoin savings, to a futures based ETF is unfair and illogical, serves no practical purpose, and should not continue. Futures based ETFs waste the investors money on friction such as rolling costs and severely underpeform spot based products. Grayscale's trust product has the highest trust factor in the world evidenced by its size. Approving the ETF will reduce Grayscale's management fee and assist all GBTC investors, current and future, in saving for retirement. Grayscale's parentcompany and its executives have innovated for the markets and have demnonstrated foresight and initiative.\"