Feb. 14, 2025
Dear Securities and Exchange Commission, I am writing to express my strong support for the proposed rule change SR-NYSEARCA-2025-08, which would allow NYSE Arca to list and trade shares of the Grayscale XRP Trust under NYSE Arca Rule 8.201-E. This approval is a critical step forward for investor protection, market efficiency, and broader adoption of digital asset investment products within a regulated framework. Investor Benefits: 1. Enhanced Market Accessibility & Investor Protection: • By approving this listing, the SEC enables investors to gain exposure to XRP through a regulated, transparent investment vehicle, rather than relying on offshore exchanges or unregulated markets. • Investors will benefit from the built-in auditing, reporting, and oversight requirements of an SEC-regulated product, reducing counterparty risks and improving security compared to direct crypto purchases. 2. Regulatory Consistency & Market Fairness: • The SEC has already approved similar trust and ETF products for Bitcoin and Ethereum. Denying XRP a similar structure would create regulatory inconsistency and an uneven playing field, despite XRP’s comparable market depth, liquidity, and institutional demand. • This approval aligns with the SEC’s mandate to ensure fair and efficient markets, while also promoting innovation in the financial sector. 3. Increased Liquidity & Institutional Participation: • XRP is one of the most widely adopted digital assets, and a publicly traded trust will unlock greater liquidity, bringing in institutional investors who require regulated products. • Institutional capital inflow into the XRP market can reduce volatility and improve price discovery, benefiting both retail and institutional investors. SEC’s Role in Market Evolution By approving this rule change, the SEC has the opportunity to bolster the U.S. capital markets’ leadership in digital assets, providing investors with more choices while maintaining the highest regulatory standards. Denying this approval could push U.S. investors toward unregulated foreign markets, increasing risks and reducing market stability. I urge the SEC to approve SR-NYSEARCA-2025-08 and set a precedent for well-regulated, transparent, and investor-friendly crypto investment products. Thank you for your time and consideration. Sincerely, Susanne Goldstein