The Security Traders Association (“STA”) appreciates the opportunity to provide
comments in response to the above-referenced notice (“Notice”) of Form 19b-4 under
the Securities Exchange Act of 1934 (as amended, the “Exchange Act”) that NYSE Arca
filed to convert Grayscale® Bitcoin Trust (“GBTC”) under NYSE Arca Rule 8.201-E as an
exchange-traded product (“ETP”). STA urges the Securities and Exchange Commission
(the “Commission”) to approve NYSE Arca’s application.

STA is an organization comprised of individuals involved in the trading of securities in
the U.S and Canada. Our members represent companies with many of the business
models in the financial services sector including, but not limited to retail brokerage
firms, equity and options market makers and liquidity providers, agency only broker
dealers, and asset owners and managers. More recently, STA has experienced a change
in the make-up of its membership. Members who were considered experts in traditional
capital markets have transitioned their careers to the digital assets markets. This
development has provided STA with subject matter expertise in such areas as the
surveillance, custody and trading of digital assets.

Read the comment letter here.