Dan M. Berkovitz, Paul Grewal, Jake Chervinsky, Justin Slaughter, and I seem to be aligned on this one, based on this CoinDesk report.
"Regulation by Enforcement" might be a lawful way to run a federal agency, as Georgetown Law Professor Chris Brummer has explained. But that doesn't make it wise. "Arbitrary and capricious" is not a good look. The SEC is at its best when it proposes and adopts regulations, and issues orders, that comply with the Administrative Procedures Act, constitutional norms, and its own rules and standards. One can hope that the SEC will return to that mode. We can agree to disagree about the value of Bitcoin and other digital commodities. That's what a market is for.