SEC issues product‑level guidance

The Securities and Exchange Commission spent this week drawing lines around two plumbing questions: when a crypto trading interface looks like a broker, and how Treasury customers can post margin across cash and futures positions. (sec.gov 1) (sec.gov 2) On April 13, 2026, staff in the Division of Trading and Markets said certain “covered user interfaces” used for crypto asset securities transactions may avoid broker-dealer registration under Section 15(a) if they meet specific conditions. The statement covers websites, browser extensions, and mobile apps that help users prepare blockchain transactions through self-custodial wallets. (sec.gov) (natlawreview.com) The staff said those interfaces must let users change default transaction settings, provide educational material, and avoid soliciting or recommending specific trades. If they show execution routes, they must show alternatives on an objective basis, disclose affiliations, and avoid labeling one route “best” or “optimal.” (pillsburylaw.com) (sec.gov) The statement is not a commission rule and, absent further action, it expires five years after April 13, 2026. The staff described it as an interim step while the commission continues to consider crypto asset securities regulation. (sec.gov) (pillsburylaw.com) That guidance follows a May 15, 2025 staff package of frequently asked questions on broker-dealer custody, capital, and transfer-agent treatment for crypto asset activities and distributed ledger technology. Commissioner Hester Peirce said at the time the answers were “incremental, not comprehensive.” (sec.gov) A day later, on April 15, 2026, the commission approved a conditional exemptive order and a related rule change to permit customer cross-margining in the United States Treasury market. The order lets certain dual registrants that are both broker-dealers and futures commission merchants offer cross-margining for cleared Treasury cash positions and related Treasury futures in a futures account, subject to conditions. (sec.gov 1) (sec.gov 2) Cross-margining means offsetting risks in two related positions so a customer does not have to post as much collateral twice. The commission said that, before April 15, only clearing members could cross-margin Treasury futures cleared at Chicago Mercantile Exchange with cash Treasury positions cleared at Fixed Income Clearing Corporation. (sec.gov) (cftc.gov) The Treasury action traces back to the commission’s December 13, 2023 Treasury clearing overhaul, which drew comments arguing that customer cross-margining could lower trading costs and support more central clearing. A January 30, 2026 notice said Fixed Income Clearing Corporation and Chicago Mercantile Exchange had asked for exemptive relief after filing their application with the commission on December 11, 2025. (sec.gov 1) (sec.gov 2) The Commodity Futures Trading Commission approved its own matching exemption on April 15, saying joint members of Chicago Mercantile Exchange and Fixed Income Clearing Corporation may hold futures customer funds in a commingled customer account at Fixed Income Clearing Corporation. DTCC, the parent of Fixed Income Clearing Corporation, and Chicago Mercantile Exchange said the program will start on April 30, 2026. (cftc.gov) (dtcc.com) Taken together, the week’s actions did not open a new enforcement case or adopt a broad new market rule. They set narrower operating terms for crypto trading front ends and Treasury clearing firms, with the next test coming in how firms redesign products and accounts around those conditions. (sec.gov) (sec.gov)