Adding legal texture to @BChillman's thread for those following the regulatory picture. @phantom's March no-action letter (CFTC Letter 26-09) already established key precedent: a non-custodial interface that provides only the technical means of access to a registered venue is not itself an introducing broker. Today's letter from @phantom and @HyperliquidPC asks the Commission to (1) codify that holding, (2) permit CFTC registrants to perform regulated functions onchain, and (3) confirm that deploying onchain smart contract infrastructure doesn't by itself trigger FCM or DCO registration. Writing settlement logic, margin accounting, or liquidation mechanisms does not, without more, make a developer a registrant. Functional equivalence alone isn't enough. This second ask is the meatiest and most operationally difficult: the custody and order-handling assumptions in the regs were written for custodial intermediaries. They don't map onto architectures where a smart contract manages margin or where settlement is atomic. The Commission needs to address this mismatch explicitly before registered venues can bring these markets to U.S. users compliantly. The mismatch also matters for users, not just registrants. Self-custody means users control their own private keys and therefore their assets. There is no intermediary, no custodial failure putting the user at risk, and no single point of compromise exposing their funds. Self-custody features aren't incidental; they're the core value proposition of onchain markets over legacy custodial infrastructure. Those features also reflect a paradigm shift in how regulators have historically regulated US financial markets. And Americans shouldn't have to give up those protections to access regulated markets. The whole point of building software onchain is that you can have both: the customer protections that come with registered venues and the security and autonomy that come with self-custody. The current regulatory gap makes that combination impossible in practice. This letter asks the Commission to close it. Registration obligations remain. They attach where they always have. Customers retain the benefits of self-custody. What changes is that the rules become administrable for how the technology actually works. Thank you to our partners at @HyperliquidPC, especially @jchervinsky and @BradBourque. We appreciate the @CFTC's willingness to tackle these difficult questions and we look forward to continuing to our engagement.