Original sourcejonesday.com
Summary
The CFTC on September 17 issued Staff Letter No. 26-25, expanding "passive software provider" no-action relief from only Phantom Technologies to all developers of software that passively connects to CFTC-regulated derivatives such as futures contracts and perpetual futures. Eligible firms may distr…
Key points
- This lets teams developing non-custodial wallets and trading front-ends compliantly access regulated derivatives markets without registering as introducing brokers, directly affecting product design.
- Regulation replaces traditional registration obligations with ten conditions, opening a compliance channel for wallet and trading tool developers while shifting responsibility to disclosure and liability agreement design.
- Developers must check each of the ten conditions and submit notice to the CFTC to claim relief, shifting product compliance costs from registration toward documentation, disclosure, and liability arrangements with registered intermediaries.
Editorial note
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