Subject: File No. SR-NYSEArca-2021-90
From: Rick Froom
Affiliation:

May. 06, 2022

Dear SEC, 


Congratulations on your approval of futures-backed bitcoin ETFs. However, a spot ETF would be a more appropriate and efficient choice for the very large number of current and potential investors who wish to hold this asset for an extended period rather than trading it on a short time frame. Grayscale Bitcoin Trust's $30bn in assets under management suggests the scale of the demand for a bitcoin spot ETF. 


In the meantime, the unavailability of a spot ETF is subjecting investors in ETNs such as GBTC to wild discounts or premiums. The discount to NAV in GBTC has been around 25% this year, representing a destruction of value of around $7.5 billion. 


By continuing to reject applications for a spot ETF, you are failing in your mission to protect the interests of investors. 


I encourage you to protect the interests of investors by approving the conversion of GBTC to an ETF. 

Sincerely, 

Richard Froom 
Austin, Texas