Subject: File No. SR-NYSEArca-2021-90
From: TCS
Affiliation: n/a

February 21, 2022

The vague assertion that a spot-ETF is prone to \"fraud and manipulation\" is without merit and has no reasonable or apparent method of being satisfied.

Even if Coinbase, Gemini, et al were brought \"under oversight\" of the SEC as regulated exchanges tomorrow, the vast majority of the world accesses and engages with the bitcoin network via exchanges that are thousands of miles from US jurisdiction. Does the SEC intend to regulate every exchange in every corner of the globe? What chance of of fraud/manipulation is permissible in the eyes of the SEC?

Should the SEC be put in charge of Major League Baseball, all MLB games would be postponed indefinitely due to the threat of rain, somewhere, at some time.

There is, after all, always a chance of rain.