Original sourceUnchained
Summary
CFTC staff issued Staff Letter No. 26-25, giving non-broker developers of 'passive software,' including self-custody wallets, a path to offer compliant derivatives trading without registering as brokers, and extending prior relief granted to Phantom Technologies to qualifying similar providers. The…
Key points
- For wallets and developers seeking to offer regulated derivatives without obtaining a broker license, this letter defines feasible conditions and compliance red lines.
- It opens the distribution path for regulated derivatives to self-custody wallets, potentially changing the entry structure for US retail derivatives trading.
- Wallet developers can design compliant order-routing features but must bear joint liability, disclosure, and marketing compliance costs; users will encounter regulated derivatives more often through wallets.
Editorial note
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