Phantom Technologies and the Hyperliquid Policy Center filed a joint comment letter with the Commodity Futures Trading Commission on July 9, asking the agency to carve out blockchain developers and non-custodial wallet providers from registration requirements built for a very different era of finance.
The core argument is straightforward: writing code is not the same as running an exchange. And a wallet that lets users access derivatives without ever holding their funds shouldn’t be regulated like a broker.
What they’re actually asking for
The letter lays out three specific recommendations, each targeting a different pressure point in the current regulatory framework.
First, Phantom and the Hyperliquid Policy Center want the CFTC to confirm that publishing onchain software does not, by itself, trigger any registration requirement. In English: if you build a smart contract and deploy it, that act alone shouldn’t force you to register as a Designated Contract Market, a clearinghouse, or a Futures Commission Merchant.
