Subject: File No. SR-NYSEArca-2021-90
From: Michael Charles
Affiliation: Individual Investor

February 19, 2022

I am an individual investor and have invested a significant amount in GBTC in my retirement accounts. I have done thousands of hours of research into bitcoin and am aware of its potential, but also the risks associated.

GBTC has been an effective (and in my opinion the best) option to gain bitcoin exposure in my retirement accounts.

However, do to the structure of GBTC, there are significant disadvantages that would be eliminated through ARCA / Grayscale's proposed conversion of GBTC to an ETP.

Primarily, conversion to an ETP would allow Grayscale to do continuous share creations and redemptions to adjust to changes in the price of the underlying asset. This would protect investors like myself from GBTC's current valuation fluctuation vs. NAV.

Recently, GBTC has been trading at 20% discount vs the value of the fund's bitcoin holdings.

Please approve conversion of GBTC to an ETP. Canada, and a growing list of countries around the world have allowed spot bitcoin ETP's. The USA should be leading in this area, not following. Our great nation has been the leader in both technology and financial services.

SEC- please act now to help US investors. Thank you.