Comment on CFTC-2026-0331, CFTC-2026-0331-0001, William, Hughes
William HughesSupportBusiness
Summary: Consensys Software Inc, the developer of the MetaMask wallet, supports the Commission's engagement on prediction markets but advocates for rules tailored to onchain architectures. They specifically request standards for oracle integrity, data quality for DCMs, portable KYC, and comprehensive smart contract security frameworks.
Six things we asked the CFTC to address:
Smart contract architecture is different. Existing DCM rules were written for centralized exchanges. AMM-based markets, oracle-based settlement, and full on-chain collateralization require purpose-built standards.
Oracle standards matter. Settlement integrity in on-chain markets depends on data feed quality. The CFTC should establish a tiered oracle standard before bad actors exploit the gap.
DCM data quality should be a regulatory requirement. Interface providers depend on accurate, timely market data from DCMs to serve users well. Clear standards would benefit the entire ecosystem.
Non-custodial wallets are not introducing brokers. The CFTC recently confirmed this for one wallet. It should be a general rule, not a privilege you have to individually apply for.
Portable KYC benefits users. Repeating full identity verification at every platform wastes users' time, multiplies their privacy exposure, and concentrates liquidity in the wrong places. The legal foundation for a better approach already exists.
Platform security needs a comprehensive framework. A pre-deployment audit is necessary but not sufficient. Smart contract management, oracle security, key management, and personnel vetting all matter.