Phantom asks CFTC to clear wallets for on-chain perps

Phantom and the Hyperliquid Policy Center filed a petition with the Commodity Futures Trading Commission on July 9 asking the agency to relax rules they say “unduly impede” fintech firms from enabling non‑custodial wallets to access registered derivatives markets. The filing seeks clear regulatory guidance on registration, on‑chain execution, and when a wallet should be exempt from introducing‑broker obligations.

The filing describes Phantom as a software interface that routes users’ order instructions to registered venues, brokers and clearinghouses while users keep control of private keys and funds. A flowchart attached to the petition shows a wallet directing orders to registered market participants. Phantom already provides access to the Hyperliquid platform through its interface in jurisdictions outside the United States; U.S. users currently do not have access.

The petition asks the CFTC for three specific clarifications. First, protocol developers and software builders should not be required to register solely because they create on‑chain software. Second, registered exchanges, futures commission merchants and clearinghouses should have a clear path to perform functions such as execution, margining and recordkeeping on public blockchains. Third, non‑custodial wallets that only provide technical access to markets should not be treated as introducing brokers if they meet conditions set out in the filing.

Phantom’s filing references a March 17 no‑action letter from the CFTC’s Market Participants Division that covered a defined software access arrangement. That staff‑level relief said division staff would not recommend enforcement against Phantom for failing to register as an introducing broker for the specific facts presented. The letter was limited to those facts and noted staff could modify, suspend or terminate the position.

To limit consumer risk and preserve oversight, the July petition attaches conditions including conflict and risk disclosures, independent user access to the registered collaborator, recordkeeping and marketing controls, and joint liability arrangements with the registered entities that receive orders. The filing states registered collaborators would retain custody, execution and clearing responsibilities.

The CFTC issued an advisory on May 29 that highlighted risks related to 24/7 trading, clearing and settlement on public blockchains and mobile apps. The advisory identified reduced liquidity at some hours, wider spreads, increased manipulation risk, and operational and cybersecurity exposures that require enhanced surveillance by registered entities and platforms that route orders to them.

In May, U.S. exchanges introduced regulated perpetual futures products for domestic investors. Global perpetual futures volume reached $61.7 trillion in 2025. The petition notes that even a small share of that global volume moving into U.S. regulated channels would represent hundreds of billions of dollars in notional trading.

The filing raises questions about where regulatory responsibilities fall when a wallet interface separates the front end from custody, execution and clearing. The commission can respond by codifying broader guidance for wallet access, by expanding relief under strict conditions tied to registered collaborators and controls, or by maintaining case‑by‑case staff-level positions that limit wallet‑based access. The CFTC will review the petition under its rulemaking and oversight processes.