For small files, it's fine, you can just use GM9, but should you need to convert a 3DS file to CIA that's bigger than what FAT32 allows, you have to do it on a computer and having just tried FOUR different methods with 3 failing miserably and the last only being able to create a file without a header, it really is annoying... Had a 4GB 3DS file and needed to convert it, ended up spending 4 hours trying!