Request for Information: Identifying Regulations to Facilitate Innovation and Competition to Financial Products and Services for Fintech Firms

Derivative Path Hedging Solutions, Inc., a registered CTA and fintech firm, supports the RFI's goal of identifying outdated regulations that hinder fintech innovation.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.

The Solana Policy Institute (SPI) supports the Commission's effort to identify regulations that impede fintech innovation and proposes three specific clarifications. They argue that non-custodial user interfaces should not be classified as intermediaries, compliance rules should be updated to reflect 24/7 onchain markets, and blockchain records should be acceptable for reporting and recordkeeping.

ProphetX LLC, a recently registered DCM and DCO, supports the Commission's efforts to facilitate fintech innovation and requests the establishment of a conditional, class-based exemption from introducing broker (IB) registration for "Qualified Technology Service Vendors" (TSVs) facilitating access to sports event contracts. They argue that the current reliance on individualized no-action letters creates regulatory uncertainty and that a class-based exemption would provide the necessary clarity for market operators and technology providers to invest in compliant infrastructure.