Phantom and the Hyperliquid Policy Center submitted a joint comment letter to the CFTC today, responding to the Commission's request for information on regulations that keep fintech firms from partnering with regulated markets.
In March, the CFTC granted Phantom no-action relief confirming that a non-custodial interface providing only the technical means of access to regulated markets does not need to register as an introducing broker. Our letter asks the Commission to build on that precedent: codify the relief for every non-custodial interface, confirm that building onchain protocol software does not by itself require registration, and give regulated exchanges and intermediaries a workable path to perform their functions onchain.
Phantom never holds user funds or controls private keys, and that design is central to the argument. Much of the current rulebook assumes an intermediary must control customer funds and orders, while onchain markets let users trade on regulated venues without giving up custody of their assets. Codifying the March relief would extend the certainty Phantom now has to every builder, and it would give Americans access to transparent open markets under rules that can be applied in practice to this innovative technology.
