$2k is ~5%; that's enough in a short enough time to trigger equity market circuit breakers and temporarily pause trading. Bitcoin has no such controls because there is no NMS regulation applied here, which is one of the SEC's fears around allowing Bitcoin ETFs.

I generally don't agree with this guidance as it is not universally applied to ETFs that the SEC has allowed historically, but it does buttress their case to a degree.

EDIT: bad math; closer to 4% price move -- although the rebound from the spike might break the threshold, current SEC rules use a trailing price band so wouldn't trigger here.

If we're just talking percentage changes, that can already happen with other commodity ETFs. I'll concede to the point that Bitcoin has historically been more volatile and could have a higher frequency of halts, but I personally don't think that should impact the formation of the ETF.

Violent agreement here, I think -- I also feel that the criteria are being applied arbitrarily and capriciously and we accept many things as ETF members that have far less liquid spot markets than Bitcoin. But incidents like this don't help.