Phantom Technologies and the Hyperliquid Policy Center filed a joint comment with the Commodity Futures Trading Commission asking the agency to update its rules for onchain market infrastructure.

The comment responds to the CFTC’s request for information on regulations that may limit fintech firms from partnering with financial infrastructure and intermediaries regulated by the Commission.

Phantom and HPC said current rules generally assume a custodial market structure where intermediaries handle customer orders and funds, while onchain markets can allow users to trade directly and retain control of their assets.

Advertisement

The groups asked the CFTC to confirm that developing or contributing to onchain protocol software does not, by itself, trigger registration with the Commission. They said registration should apply to firms that actually handle customer orders or funds, or enter into transactions with customers, rather than to software protocols or developers standing alone.

Phantom and HPC also asked the CFTC to give registered exchanges, clearing organizations and intermediaries a path to use onchain infrastructure for regulated functions.

The comment said designated contract markets should be able to use onchain protocols for matching and execution, while derivatives clearing organizations should be able to use them for margining, settlement, clearing and default management.

The filing also calls on the CFTC to turn its recent Phantom no action letter into a formal rule. That letter granted relief to Phantom as a non custodial wallet provider whose role is limited to providing technical access to regulated markets. Phantom and HPC said a rulemaking would give similar wallet and front end providers broader certainty.

Phantom said it does not hold user funds, control private keys, execute trades between users or intermediate transactions. HPC described itself as an advocacy group focused on creating a regulated path for Americans to access onchain markets, including those available on Hyperliquid.

Phantom integrates Hyperliquid through its interface, though the functionality is not available to US users. The groups said they are working together to support regulations that would allow Americans to access onchain derivatives markets under CFTC oversight.