On April 13, the SEC advanced the crypto market structure independently of congressional action by releasing a staff statement regarding Covered User Interfaces. This includes websites and apps that aid users in self-custodial crypto transactions with securities.
The Division of Trading and Markets clarified it would not object to these providers operating without broker-dealer registration under Exchange Act Section 15, provided they adhere to specific behavioral and disclosure guidelines.
This development marks the first time the SEC has outlined how wallet-linked crypto trading apps can function around securities without full broker licenses, contingent on avoiding execution, custody, or activities resembling DeFi. This guidance allows for immediate product launches while indicating that comprehensive protocols remain in a different regulatory category pending further action by Congress or the Commission.
The statement specifies that a Covered User Interface Provider qualifies if it enables user customization of transaction parameters, refrains from soliciting specific trades, and relies on pre-disclosed routing logic. It also allows connections to distributed ledger trading systems like AMM liquidity pools.
For tokenized securities developers, this creates a narrow framework for software facilitating user preferences, route inspections, price comparisons, and self-custodial wallet signings, while prohibiting any form of intermediation such as recommendations or discretionary order routing.
The SEC’s guidance explicitly states that intermediary business models require broker registration, even if the wallet is self-custodial. The relief applies to a specific product shape, leaving broader on-chain trading outside its scope.
This statement is part of a three-part SEC campaign aimed at clarifying federal securities laws for crypto assets, following earlier statements in January and March. Commissioner Hester Peirce and Trading and Markets Director Jamie Selway highlighted the incremental progress toward establishing infrastructure for tokenized securities and crypto market structure.
With real volume already present in markets like RWA.xyz, DTCC is preparing a tokenization service for mid-2026, while the SEC outlines rules for an active user base. The document’s five-year expiration underscores its provisional nature, dependent on future Commission action or legislative intervention.
The future of product design could see operational trading within a bounded regulatory framework if the SEC issues further exemptions. Conversely, caution may lead to limited application of the guidelines, with serious trading focusing on permissioned pilots and registered entities.
The need for Congressional action is evident, as highlighted by Senate Banking’s postponed markup and Treasury Secretary Scott Bessent’s support for the CLARITY Act. Industry stakeholders have voiced differing needs: SEC staff emphasize immediate market movement under existing authority; the crypto-native industry seeks conditional AMM relief; incumbents push for durable rulemaking with investor protection.
Chairman Atkins has framed Project Crypto as complementary to legislative efforts, making Congressional resolution essential yet challenging due to varying stakeholder interests.