Bitwise Investments chief investment officer Matt Hougan has expressed skepticism about the inclusion of surveillance sharing agreements in spot bitcoin ETF proposals from competing firms. He believes that these agreements might not necessarily guarantee regulatory approval. In response, Bitwise has added 40-plus pages of research to address the US Securities and Exchange Commission’s concerns over various bitcoin ETF filings. The research aims to prove that the bitcoin futures market leads price discovery over the spot market and is a regulated market of significant size. The filing also mentions that while the Commission rejected the view that this logic extends to spot bitcoin ETPs, this view was recently rejected by the Court of Appeals for the DC Circuit. However, the SEC still has the option to appeal the court’s decision. Proposed issuers of spot bitcoin ETFs need to demonstrate that the CME bitcoin futures market leads price discovery and is a regulated market of significant size. Bitwise argues that there is a high degree of consensus among various studies showing that the CME futures market leads the spot market. Overall, Bitwise’s new research aims to address the gaps in rival bitcoin ETF proposals.

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