RIADeFi

CFTC staff grants conditional registration relief for self-custodial wallet software

Regulation · · Ketju Research

U.S. Commodity Futures Trading Commission

What changed

CFTC market-participant staff granted a conditional no-action position from introducing-broker and associated-person registration for a self-custodial wallet software provider facilitating trading with registered intermediaries and markets.

Who it affects

  • Wallet providers, FCMs, IBs, DCMs, and advisers assessing self-custodial trading tools

What is still open

  • The limits of the conditions and whether comparable providers will receive relief

What it means for an advisor

  • Verify that any relied-on arrangement fits the letter’s facts and conditions.

Sources

  1. 26-09 Letter Type : No-Action Division : MPD Regulation Parts : 4d, 4k, 3.10, 3.12 Tags : DCM, FCM, IB, Registration, Associated Persons, solicit Issuance Date : 03/17/2026 Description : MPD no-action position, subject to certain specified conditions, on introducing broker (IB) and associated person registration for a provider of self-custodial crypto asset wallet software that proposes to provide and market software to facilitate trading by its users with registered futures commission merchants · U.S. Commodity Futures Trading Commission ·

Version 1, published . Educational analysis, not legal advice.