Peirce Commends Crypto Interface Guidance, Permanent Regulation Needed
Summary
Commissioner Hester M. Peirce issued a statement commending the SEC Division of Trading and Markets' staff statement clarifying when interface providers (front ends and self-custodial wallets) may operate without registering as broker-dealers under Section 15(b) of the Exchange Act. Peirce expressed preference for more permanent regulatory rulemaking rather than relying on staff-level no-action guidance to address broker definition in light of new technologies. She called on the public to engage with the Commission and provide views on how terms like 'broker' should apply to crypto asset securities transactions.
What changed
Commissioner Hester M. Peirce issued a statement commenting on the SEC Division of Trading and Markets' staff statement regarding broker-dealer registration for certain user interfaces in crypto asset securities transactions. The staff statement outlines circumstances under which it will not object to interface providers operating without registering as broker-dealers under Section 15(b) of the Exchange Act. Peirce commends the staff guidance as helpful but advocates for more permanent formal rulemaking to address the broker definition in light of current market circumstances. She notes the law is already clear that wallets and interfaces do not become 'brokers' solely because they enable users to create or control self-custody wallets, transmit blockchain instructions, view onchain prices, or format messages for users to sign from a self-custody wallet.\n\nFor compliance purposes, broker-dealers and crypto interface providers should note that the Division's existing staff guidance remains operative. Peirce's statement signals continued regulatory interest in this space and her preference for formal rulemaking could signal future regulatory direction. The Commission is soliciting public feedback to inform future rulemaking assessing terms like 'broker' against new technologies. Parties affected by broker-dealer registration requirements for crypto asset securities transactions should monitor for developments and consider engaging with the SEC.
What to do next
- Monitor SEC Division of Trading and Markets guidance on broker-dealer registration for crypto user interfaces
- Engage with the SEC by providing views and recommendations on how the broker definition should apply to crypto asset securities transactions
- Stay informed about potential future SEC rulemaking on broker-dealer registration for crypto interfaces
Archived snapshot
Apr 14, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
Statement
Interfacing with our Inner Demons: Comments on the Division of Trading and Markets' Statement on Certain User Interfaces
April 13, 2026
I commend the Division of Trading and Markets for its statement on front ends and self-custodial wallets used by investors in onchain crypto asset securities transactions. [1] Specifically, the staff lays out circumstances in which it will not object to an interface provider creating, offering, and/or operating an interface without registering as a broker-dealer pursuant to Section 15(b) of the Exchange Act. While the staff expressing its view is helpful, I favor a more permanent regulatory approach that addresses the broker definition in light of current market circumstances.
The law is already clear that wallets and interfaces do not become “brokers” solely because they enable users to create or control self-custody wallets or transmit instructions to a blockchain; allow users to view onchain prices or data; or format messages for users to sign or approve from a self-custody wallet. [2]
Crypto is forcing the Commission to confront its inner demons that have driven it toward ever more expansive readings of the securities laws. Recent history is littered with a patchwork of no-action letters and enforcement actions that have contorted the term “broker” beyond recognition. As I wrote in dissent to one such enforcement action: “The problem with requiring anyone whose products and services touch the financial services industry to [register or] come in for no-action relief is that it dissuades people from applying their ingenuity to serving the securities industry.” [3]
People have shown great ingenuity in developing crypto wallets and front ends that serve users well. It would be a shame if investors in crypto asset securities transactions were unable to use these tools because of an overly broad reading of the term “broker.”
The Commission needs public feedback to inform future rulemaking to assess terms like “broker” against the backdrop of new technologies. Please engage with us and provide us with your views and recommendations.
[1] Staff Statement Regarding Broker-Dealer Registration of Certain User Interfaces Utilized to Prepare Transactions in Crypto Asset Securities (April 13, 2026), https://www.sec.gov/newsroom/speeches-statements/staff-statement-regarding-broker-dealer-registration-certain-user-interfaces-utilized-prepare-staff-statement-regarding-broker-dealer-registration-certain-user-interfaces-utilized.
[2] See SEC v. Coinbase Inc., 726 F. Supp. 3d. 260, 304-07 (S.D.N.Y. 2024) (rejecting arguments that a wallet service that charged a 1% transaction fee was a securities “broker”).
[3] Commissioner Hester M. Peirce, Statement Regarding Neovest, Inc. (June 29, 2021), https://www.sec.gov/newsroom/speeches-statements/peirce-statement-neovest-062921.
Last Reviewed or Updated: April 13, 2026
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