Subject: File No. SR-NYSEArca-2021-90
From: Douglas Shultz
Affiliation: (Elected) Escondido City Treasurer / Wealth Manager, Yorkshire Wealth Management

February 14, 2022

Every day I have clients ask me about cryptocurrency and Bitcoin specifically. Right now my US options are generally BITO at .95% or GBTC at 2%. Being able to have an option that reduces this fee substantially and participation in the direct ownership of Bitcoin will allow clients the proper exposure they desire, similar to a gold spot ETF.

The cryptocurrency market has passed silver in terms of total market capitalization at various times. If silver can't be manipulated at these levels, neither can Bitcoin.

It's appropriate to allow a spot Bitcoin ETF product considering a Bitcoin futures ETF has already been approved. the Bitcoin spot ETF will ensure lower fee's and give clients what they desire, spot Bitcoin exposure. The SEC hinders my ability to perform as a fiduciary when a client tells me they want to own Bitcoin directly and the only option is an expensive OTC security.

I support the conversion of GBTC to a spot ETF as well as many other elected officials and wealth managers. Please approve this conversion and also work with congress to provide direction in regards to crypto.