Here’s an image of what that letter actually says. (Keep in mind I am not a lawyer but I sometimes pretend to understand this stuff and will do my best) Essentially, the SEC seems to be saying that the clever legal and regulatory moves used to wedge this thing through have actually made it so that the fund doesn’t qualify under rule 6c-11. Rule 6c-11 is commonly known as “The ETF Rule”. It’s what makes 1940 Act funds (like the one filed here and other futures products) not have to go through that long drawn out 19b-4 process with deadlines and delays that you’re used to hearing about with regards to spot crypto products in the US. (The rule does more than that but this is the relevant part for now) SEC seems to be saying/arguing that these products likely don’t qualify for 6c-11 and therefore cannot list as structured.