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ARTICLE · 13 APRIL 2026

SEC Staff Carves Out A Path: Crypto Interface Providers May Not Be Broker-Dealers

Jones Day
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The SEC Staff has issued groundbreaking guidance establishing conditions under which DeFi front ends and self-custodial wallet trading interfaces can operate without broker-dealer registration. This framework permits transaction-based compensation for covered user interface providers while imposing strict operational requirements and prohibitions. The guidance represents a significant five-year experiment in crypto regulation that could reshape how broker-dealer status is determined across the financial ind

United StatesTechnology
Nathan Brownback
Nathan Brownback
Michael Dawson
Michael Dawson
Abradat Kamalpour
Abradat Kamalpour
Nicholas Podsiadly
Nicholas Podsiadly
Laura S. Pruitt
Laura S. Pruitt
Mark W. Rasmussen
Mark W. Rasmussen
Trevin Crider
Trevin Crider
Paul R. DiPadua
Paul R. DiPadua
Michael Rust
Michael Rust
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In Short

The Situation: On April 13, 2026, the Staff of the SEC's Division of Trading and Markets issued guidance (the "Guidance") setting out the conditions under which providers of covered user interfaces ("CUIs"), including DeFi front ends and self-custodial wallet-embedded trading tools, may operate without registering as broker-dealers under Section 15(a) of the Securities Exchange Act of 1934.

The Change: The Guidance establishes a no-action framework for covered user interface providers ("CUI Providers") that meet specified conditions. In a significant departure from the traditional broker-dealer analysis, the Guidance permits CUI Providers to receive transaction-based compensation from users without having to register as broker-dealers.

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