Overview
- Staff Letter No. 26-09 from the CFTC’s Market Participants Division says it will not recommend action against Phantom for failing to register as an introducing broker under its described model.
- Relief depends on users submitting orders to CFTC-regulated designated contract markets through registered entities, with Phantom prohibited from controlling customer assets.
- Phantom must provide risk disclosures, maintain marketing and communications compliance policies, and keep records tied to its derivatives-related activities.
- The position covers regulated futures access only and does not extend to DeFi derivatives or tokenized prediction markets, with no guidance on unregulated integrations.
- The relief is narrow, case-specific, and subject to reassessment or future rulemaking, and Phantom says orders will flow directly to exchanges via registered partners under its interface-only design.