On July 9, Phantom submitted a letter to the CFTC requesting clarification on rules it says impede fintech firms from using registered derivatives markets. Phantom asked that protocol developers avoid triggering registration requirements for on‑chain software, that registered exchanges and clearinghouses receive a clear path to execute, margin and recordkeeping functions on public blockchains, and that non‑custodial wallets not be treated as introducing brokers when they provide only technical market access. The letter also outlined conditions such as conflict disclosures, risk disclosures, independent user access, and recordkeeping and marketing controls. The CFTC’s Market Participants Division issued Phantom no‑action relief on March 17, meaning staff would not recommend enforcement if Phantom failed to register as an introducing broker for software that provides access to registered futures commission merchants, introducing brokers, and designated contract markets. The relief is non‑binding and may be modified, suspended, or terminated. Phantom proposes that regulated perpetual futures and event contracts could be accessed through a wallet app that users already use to hold tokens. The wallet would serve as a front‑end interface; orders would be routed directly to registered entities that hold assets and execute trades. Custody would remain with brokers, futures commission merchants, or exchanges, and the wallet would not hold margin or customer funds. The CFTC’s May 29 advisory warned that continuous trading on blockchain networks, stablecoins, and smartphone apps can create risks such as reduced liquidity, wider spreads, increased manipulation risk, and operational and cybersecurity challenges. It noted that most consumer‑facing apps are only beginning to build the surveillance capabilities required for real‑time monitoring. Coinbase and Kalshi began offering regulated perpetual crypto futures to U.S. investors in May, marking the first availability of such products on domestic regulated exchanges. Global perpetual futures trading volume reached $61.7 trillion in 2025; a 1 % shift into regulated U.S. channels would equal about $617 billion, and a 5 % shift would exceed $3 trillion. A bullish outcome would see broader CFTC guidance allowing many wallets to connect directly to registered venues, increasing distribution power for wallets and potentially reducing reliance on offshore venues. A bearish outcome would maintain limited access, with U.S. users needing broker or exchange accounts for regulated products while on‑chain perpetuals remain offshore or geofenced, preserving the role of traditional brokers and exchanges.