Hyperliquid Policy Center and Phantom filed a July 9, 2026 comment to the CFTC's fintech RFI asking the agency to recognize onchain protocol software as infrastructure, not a registrant by default. They want three things: no registration just for publishing or contributing protocol code, guidance for DCMs, DCOs, and FCMs using onchain execution and clearing, and a rule codifying Phantom's March 17 no-action relief for non-custodial front ends. That would put U.S. access to Hyperliquid-style derivatives inside CFTC oversight while keeping compliance duties on regulated actors, not wallet or protocol developers.

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