Subject: File No. SR-NYSEArca-2021-90
From: Matthew McManmon
Affiliation: Strategic Sourcing Consultant

February 15, 2022

The Grayscale Trust should be allowed to convert into a spot ETF. The reason myself and many other investors were initially drawn to the GBTC is due to the ease of owning it in an IRA account. The process of creating an IRA at alternative financial institutions is expensive and onerous. The reality is, most investors own BTC directly in their own custody or held at exchanges, but to reap the benefits of IRA via regular brokerages such as Fidelity we can only own GBTC to get exposure to Bitcoin. Other countries have already have spot Bitcoin ETF and it seems like the SEC's reluctance to approve this has disadvantaged US investors and harmed the investors of GBTC as it now trades at a discount to the actual bitcoin held. Please immediately approve the conversion of GBTC trust to a spot ETF. Thanks.