Eligible interfaces may display market data and possible execution routes, but their software must use objective, disclosed and independently verifiable parameters. Users must be able to customise default transaction settings and view alternative routes where available.
Providers must not recommend particular investments, solicit users to undertake specific securities transactions or describe one execution route as offering the ‘best price’ or being the ‘most reliable’. Any affiliation with a trading venue must be disclosed.
Fees must be fixed, consistently applied and independent of the asset, counterparty, venue or execution route. Providers cannot receive payments for order flow or compensation from third parties based on the size, value or occurrence of a transaction.
The statement also requires extensive disclosures covering fees, conflicts of interest, default transaction parameters, cybersecurity controls, the protection of trading information and connections with trading venues. Users must be informed that the interface provider is not registered with or regulated by the SEC for the covered activity.
The staff position does not extend to providers that give investment advice, negotiate transaction terms, arrange financing, hold customer assets, take or route orders, or execute and settle transactions on behalf of users.
The statement does not constitute an SEC rule, regulation or formal Commission guidance. It creates no new legal rights or obligations and will be treated as withdrawn on 13 April 2031 unless the Commission takes intervening action.
Why does it matter?
The staff position provides a provisional boundary between software that helps users prepare their own on-chain transactions and services performing functions associated with regulated securities intermediaries.
The distinction could reduce uncertainty for some developers, but the protection is narrow and conditional. Providers must satisfy detailed operational and disclosure requirements, while the Commission remains free to adopt a different position through future rulemaking.
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