Subject: File No. SR-NYSEArca-2021-90

February 22, 2022

Dear SEC,

I believe the time has come for a spot bitcoin ETF. The futures-based products the SEC has approved are costly alternatives that hurt the average investor. The contango in the bitcoin futures curve creates an extremely costly roll premium. Investors deserve better. As a result, the SEC should support and approve the conversion of the Grayscale Bitcoin Trust (GBTC) to a spot bitcoin ETF.

Sincerely,


Adam Thurgood, CFA, CFP®
Managing Partner | Hightower Las Vegas