Subject: "File No. SR-NYSEArca-2021-90"
From: Daniel Warsh
Affiliation:

May. 09, 2022

To whom it may concern, 


I have been part of trading and investing in the capital markets for 40 years. I have seen many different products come and go. Triple leveraged, double short levered, ETF that raise money to pay their investors dividends, etc etc. The SEC role is to protect the investor. I do understand this, but over the years many of these products have not been understandable nor more importantly transparent. I do read the prospectuses, but most do not include the SEC. 


This all said, GBTC is transparent in every way. This security has been out there for many years as a Trust product. At first, the Trust was trading 100% above it's NAV and now it trades under its NAV. It is unknown why the SEC has been reluctant to approve this as an ETF, but I am sure the SEC has its reasons. 


I suggest that you approve this product or provide a detailed reason why a futures ETF trades and not an equity (with 23 Billion in NAV) is allowed to trade. I figure most things out but this is puzzling to me. 


Please allow the GBTC to become an ETF so that, the fees move lower for all investors and the NAV will trade properly in both directions. 


Kind Regards 


Daniel 









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Daniel I Warsh 
Warberg Asset Management