Subject: File No. SR-NYSEArca-2021-90
From: Mike Tocci
Affiliation:

May. 03, 2022



Dear SEC,

I am a long time GBTC shareholder and absolutely believe that GBTC should covert to a spot ETF.  In my opinion a futures ETF which was approved is a far inferior product than a spot ETF.  If consumer protection is TRULY the SEC’s concern a spot ETF would then be approved.  The futures etf has roll over premium every month and does not trade in lock step with the spot price of bitcoin.  Grayscale should be the first spot etf approved as they are a leader in the space and have the most liquid product.  I believe grayscale already holds approx 600k bitcoin in the trust.  If the spot etf is rejected I hope grayscale will take steps for legal action as it seems that it’s not being treated the same as other products.

Thank you

Mike Tocci.