# A Major Win for #البيتكوين Open-Source Self-Custodial Wallet Developers and Users

The U.S. Commodity Futures Trading Commission (CFTC) just announced that self-custodial wallet developers do not need to register as intermediaries.

Phantom wallet received a "no-action letter," stating that the agency will not pursue legal action against self-custodial wallet developers who connect users to regulated trading platforms, as long as they do not hold user funds. This is the first time the agency has formally acknowledged such a matter.

Why does this matter?
Under current U.S. law, any entity that promotes or facilitates derivatives trading must typically register as a registered intermediary with the agency. This rule was originally written for traditional intermediaries in the financial system. But as self-custodial wallets began integrating access to derivatives markets, developers found themselves in a legal gray area—they could have been classified as unregistered intermediaries simply for writing software.

The agency's position has become clear: If your wallet software connects users to registered entities like futures commission merchants or regulated markets, and you don't hold user funds, then you're not an intermediary… you're a software provider.

The timing is no accident. A week ago, CFTC Chair Mike Ciligie said at the FIA conference in Boca Raton: "For a long time, there has been an open question about whether software providers are subject to registration requirements with the agency. We intend to address this question directly." Just 7 days later, it was done.

The significance extends far beyond Phantom wallet. Now every self-custodial wallet developer and every open protocol interface that connects users to regulated markets has a clear reference: "Write software, don't hold funds, connect users to registered entities… and the agency won't pursue you."

For comparison, previously vague rules about "intermediaries" were used as a tool against developers. Tornado Cash developers were prosecuted, user interfaces were proactively shut down, creating a hostile environment that pushed many developers to work outside the United States.

This letter, combined with Ciligie's end to the struggle between regulatory agencies through the crypto project, signals a complete shift in approach.

The United States is now clearly trying to win back developers instead of driving them away.

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