CFTC SAFE-HARBOR

CFTC Passive Derivatives Software Scope & Compliance Builder

Source: @WatcherGuru Direct Rule Interpretation
System Architecture & Features
Preset Configurations:
Derivative Simulation & Execution Isolation
Evaluating simulated crypto perpetual synthetic orders with selected software perimeter.
0% (Self-Custodial)
Custody Exposure
Passive Display
Execution Channel
Decentralized
Settlement Layer
CFTC Safe Harbor Determination
2026-09-17 UTC
Exempt Safe Harbor Broker Registration: NOT REQUIRED
Exempt Passive Software
The modeled software qualifies under the CFTC passive developer safe harbor. Because software does not take custody of customer margin, route orders, or execute transactions, developer registration as an Introducing Broker (IB) or Futures Commission Merchant (FCM) is not required.
Active Broker Triggers
0
Regulatory Risk Profile
Low Risk (Non-Intermediary)
Statutory Trigger Audit Ledger
7 U.S.C. § 1a(28) Custody / Margin Hold: PASSED (Non-Custodial)
CFTC Reg 1.3 Introducing Broker (IB) Solicitation: PASSED (No Routing)
CFTC Reg 4.14 Commodity Trading Advisor (CTA): PASSED (Impersonal Code)
Designated Contract Market (DCM) Order Matching: PASSED (Pure Node/P2P)
Architectural Guidance & Safe Harbor Clause

Fully compliant with developer safe harbor provisions for passive tools. Maintain air-gapped non-custodial parameters and ensure user interfaces sign payload transactions purely on client hardware.

Includes full parameters, CFTC triggers assessment, and immutable hash for audit trails.
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