Key Highlights
- Solana Policy Institute submitted recommendations to the CFTC as part of its fintech regulatory review.
- The group asked regulators to clarify that non-custodial wallets should not be treated as financial intermediaries.
- It also proposed updating compliance rules to reflect the fact that blockchain markets operate 24/7.
The Solana Policy Institute (SPI) has asked the Commodity Futures Trading Commission (CFTC) to revise several regulations affecting blockchain businesses, arguing that parts of the agency’s framework no longer reflect how digital asset markets operate.
In a letter submitted to the CFTC on Thursday, the digital asset advocacy group responded to the agency’s request for information on regulations that may create unnecessary barriers for fintech firms. The filing focuses on three areas the organization believes would benefit from clarification: non-custodial wallet software, continuous blockchain markets, and blockchain-based recordkeeping.
SPI seeks clarity on wallet software
A major portion of the submission centers on non-custodial crypto wallets and blockchain user interfaces. SPI argued that software providers that help users prepare and broadcast blockchain transactions should not automatically be classified as introducing brokers or associated persons under existing commodities regulations.
According to the filing, those registration requirements were designed for firms that accept customer orders or hold customer assets rather than developers building self-custody software. The organization asked the CFTC to issue guidance confirming that software providers are not required to register solely for helping users submit their own blockchain transactions.
Proposal targets legacy timing rules
SPI also said several CFTC rules still assume markets operate only during business days and business hours, while blockchain networks function continuously. The filing recommends updating compliance frameworks that rely on traditional market hours so they better reflect markets where trading, settlement, collateral movements, and liquidations can occur at any time.
The group also suggested allowing UTC- or calendar-based compliance standards where appropriate for blockchain-based activity.
Using blockchain records for compliance
Another proposal relates to reporting and recordkeeping requirements. SPI argued that blockchain transactions already generate permanent, timestamped records that can be independently verified, reducing the need to duplicate the same information in separate off-chain reports.
The submission asks the CFTC to clarify that regulated firms may use reliable blockchain records to satisfy certain reporting, audit trail, and recordkeeping requirements where the data is complete and accessible. SPI noted that information unsuitable for public blockchains could continue to be maintained through traditional reporting systems.
Part of broader U.S. crypto regulatory review
The recommendations were submitted as part of the CFTC’s ongoing review of regulations that may affect financial technology companies. The agency is seeking feedback on rules, guidance, and staff positions that could unnecessarily hinder innovation while preserving market integrity, customer protection, and financial oversight.
SPI argued that its proposals could be implemented through interpretive guidance, no-action relief, or the CFTC’s existing exemptive authority without requiring amendments to the Commodity Exchange Act.
The submission also comes as U.S. regulators reassess how existing financial rules apply to digital assets. Last month, the CFTC and the U.S. Securities and Exchange Commission (SEC) launched a joint review of crypto derivatives regulations to clarify how current rules governing securities, swaps, and blockchain-based derivatives should apply to digital asset markets, while helping define the agencies’ respective jurisdictions.
Against that backdrop, SPI’s recommendations focus on areas where it believes CFTC regulations have not kept pace with blockchain technology, particularly around self-custody software, continuously operating markets, and blockchain-native recordkeeping.
Also Read: Kalshi Pushes Perpetual Futures Beyond Crypto With CFTC Talks
