Subject: File No. SR-NYSEArca-2021-90
From: Paul Christy
Affiliation:

Apr. 22, 2022

 



I support the company's application. The directors of Grayscale Bitcoin Trust (GBTC) have applied for GBTC to convert to an Exchange Traded Fund (ETF). 

Insofar as the SEC has yet to approve the instantiation of a spot bitcoin ETF, but has maintained its approval of futures trading ETF to the diminution of value held by retail traders, I feel there are advantages to both retail investors and institutional holders that spot ETFs exist. I offer as evidence of one advantage -- futures-based crypto ETFs distribute random payments to holders that have no clear tax treatment under IRS rules. A standard of distribution based on transactions or sales of one asset are far more simple in accounting. 

Thank you. 
Paul Christy