Subject: File No. SR-NYSEArca-2021-90
From: James Dall
Affiliation: Retired

February 14, 2022

GBTC should be approved as an ETP (ETF). The change would greatly improve the transparency of the product and allow investors more direct access to bitcoin at a price that reflects the market price of bitcoin. I am not concerned about manipulation as a result of this change and feel that manipulation would be decreased. An ETF would provide easier and less expensive access than other options like a bitcoin wallet.

The fact that there is an approved bitcoin ETF that uses derivatives only supports the approval of a spot ETP. By any measure a derivatives product is more complex and if investors can handle that than they can certainly understand and handle a spot based product.

Investors are looking for a straightforward access to bitcoin and other crypto currencies and upgrading GBTC to an ETF would accomplish this objective.

Thank you,
James Dall