The core argument in favor of approving a spot bitcoin ETF, at the least presently, is that the SEC’s considerations about manipulation are actually inconsistent – and presumably in violation of the Administrative Process Act, as Ribbit Capital’s Sigal Mandelker and Jessi Brooks wrote. The company has already authorised exchange-traded merchandise that use bitcoin futures contracts, notably NYSE Arca’s proposal to record and commerce shares of the Teucrium Bitcoin Futures Fund and Nasdaq’s proposal to record and commerce shares of the Valkyrie XBTO Bitcoin Futures Fund. Each of the funds present “surveillance-sharing agreements” designed to forestall manipulation, which the SEC says each spot BTC utility has lacked.