To the best of my knowledge, all of them.

This is law, not an undergraduate philosophy of logic class. "Proof" in these contexts means providing supporting or contradictory evidence; the SEC is stating that a company that wishes to offer a spot Bitcoin ETF must provide sufficient evidence that contradicts the other evidence that Bitcoin's market is susceptible to fraud and manipulation.

Edit: The SEC lays out some of this evidence on pages 22ff.

And all the metals markets have massive indictments and settlements about how they were full of fraud and manipulation. Where the only difference is that this all came out after spot metals ETFs were approved.

The SEC is gatekeeping one specific market.

> all the metals markets have massive indictments and settlements about how they were full of fraud and manipulation

Right. That’s the point. Indictments and settlements.

Meanwhile, we know e.g. Tether and its affiliates lied materially, they said as much to the New York DA. Yet no enforcement action. No oversight.

That’s a stretch, there have been many indictments and settlements from the state - including multiple governments in the US and multiple agencies of the Federal government on things that affect the crypto markets, including regarding Tether, and including participants that will affect the price of bitcoin.

The SEC is gatekeeping this specific market based on an accidental and optional administrative purview that should be corrected.