Moving the bar from "This machine can be subverted by anybody who can access the SPI bus" to "This machine can be subverted by anybody who can solder on additional hardware that intercepts and modified bus activity" is still significant.
(Or rootkit the "trusted" usb stick)
If you're willing to accept stateful storage for the TPM then I agree this is straightforward, but then I don't think the "stateless device" has been achieved. If you're willing to trust the TPM's storage then you could have just used that to establish trust for everything (which is the status quo on chromebooks).