The letter also calls on the regulator to “nurture a competitive financial marketplace” by restoring predictable timelines.
The letter argued that departures from the queue began in October 2021, when the ProShares Bitcoin Futures Fund received a three-day head start and secured more than 90% of the market share.
The firms contend that such timing favors issuers with deeper distribution networks, encourages copycat filings, and concentrates assets under bigger brands.
The authors said the pattern harms market integrity by weakening incentives for original research and discouraging smaller sponsors from taking early risks.
They also noted that honoring filing dates would not add material strain on SEC staff because registration statements already arrive in sequence and can retain their original time gaps through the review cycle.
He added that refusing to follow this standard “creates an uneven playing field for issuers who filed earlier and had to wait longer.”
