Comment on CFTC-2026-1321, CFTC-2026-1321-0001, dYdX Trading Inc. dba dYdX Labs

Summary: dYdX Labs, a U.S.-based Fintech firm, argues that the CFTC should streamline and adjust regulations to accommodate the unique technological features of decentralized finance (DeFi) protocols. They advocate for recognizing on-chain settlement, automated risk management, and distributed ledger records as valid substitutes for traditional regulatory requirements like mandatory clearing and recordkeeping.