Subject: File No. SR-NYSEArca-2021-90
From: Richard Ashley
Affiliation:

May. 06, 2022

Dear Sirs, 


There are no valid reasons to deny Grayscale Bitcoin Trust's application to convert its product into an ETF and substantial advantages would accrue to investors.  In particular, the product would then track the value of the underlying asset more closely.  Other products, based on bitcoin futures do not do this and are clearly subject to market manipulation -- what purpose is served by forcing investors to deal with only these investment vehicles? 


Richard Ashley