CTF Written Submission

Re: Non-Custodial Trading Interfaces Should Not be Considered “Brokers” or “Exchanges” under Federal Securities Laws

May 20, 2025
  • Non-custodial trading interfaces (NTIs) should not be considered "brokers" or "exchanges" under federal securities laws as they do not control or custody user funds, solicit transactions, or provide personalized investment recommendations.
  • NTIs act solely as technological tools that enable users to draft and optimize transactions without intermediating trades or exercising control over the underlying protocol.
  • The SEC is requested to issue guidance confirming that NTIs are not required to register as brokers or exchanges, ensuring clarity and fostering innovation in non-custodial platforms.

Last Reviewed or Updated: May 20, 2025