Comment on CFTC-2026-1321, CFTC-2026-1321-0001, Derivative Path Hedging Solutions, Inc.
Derivative Path Hedging Solutions, Inc.SupportBusiness
Summary: Derivative Path Hedging Solutions, Inc., a registered CTA and fintech firm, supports the RFI's goal of identifying outdated regulations that hinder fintech innovation. They specifically argue that longstanding interpretive guidance regarding "Introducing Broker" (IB) definitions is overly broad and should be updated to exempt entities that do not provide derivatives advice or have a derivatives business line from registration requirements.
Staff’s longstanding interpretive guidance of the CEA and Commission’s definitions of Introducing Broker (“IB”) may, by its broad terms, capture unintended entities that seek to make referrals of prospective, institutional swap advisory customers to technology-focused CTAs, with unintended consequences. Derivative Path Hedging Solutions, Inc. -- a Commission-registered CTA -- respectfully submits the attached comment letter in support.