Subject: File No. SR-NYSEArca-2021-90
From: Joseph DeFilippis

February 15, 2022

I write in support of the application by NYSE Arca Inc. to convert the Grayscale BTC Trust to an ETF.

As a retail investor, I seek opportunities to grow and preserve my wealth by taking calculated risks and diversifying my assets. To this end, it is important that I be able to invest in new asset classes when I believe that they present an acceptable balance of risk and potential reward.

I understand the risks associated with investing in digital assets, and I have thoughtfully chosen to allocate a portion of my assets to bitcoin. I decided to invest in Grayscale BTC Trust because they are capable of storing and protecting the underlying asset against theft or loss, much like physical gold ETFs. I prefer entrusting them with this responsibility. Furthermore, I am able to conveniently buy or sell shares through my IRA brokerage while I cannot buy bitcoin directly. If a spot bitcoin ETP were available and had lower fees, I might have chosen that investment. Instead, I chose the best available alternative.

Now that the Commission has allowed the trading of ETPs based on bitcoin futures contracts, this gives me another new alternative. However, I do not wish to invest in futures because they have additional cost, risk, and complexity. I would prefer to trade based on the spot price of bitcoin. I believe it is fair and logical that an ETP based on spot price also be approved.

I know it is your duty to protect me and other investors, and I appreciate your efforts against manipulation and deceit. Respectfully, I also believe that too much regulation harms me and other investors who have done due diligence and have accepted the risk. Too much regulation limits our options, costs us more money, and forces us to find workarounds that may introduce additional unnecessary risk.

Please approve this application and allow me and other investors to invest in bitcoin more efficiently using this ETP.

Signed,
Joseph DeFilippis