Wintermute's letter to the SEC: Traders should be allowed to manage their own on-chain settlement processes; self-operated trading on DeFi should not require registration.

According to Mars Finance, Wintertermute's latest comment letter to the SEC's Crypto Assets Task Force explicitly states two main points: 1. Allowing self-managed on-chain settlement processes: Wintertermute urges the SEC to clarify that regulated traders should not be considered in violation of rules for bypassing traditional clearinghouses when conducting on-chain settlements for their own accounts. As long as the trading counterparty can independently manage its wallet and conduct on-chain delivery, and the trader fulfills its obligations promptly, it should be exempt from the Customer Funds Protection Rule. This approach significantly reduces intermediary layers and improves blockchain settlement efficiency. 2. Proprietary trading on DeFi does not require registration as a trader: Wintertermute emphasizes that engaging in proprietary trading (including liquidity provision) solely on DeFi protocols, without interacting with clients, undertaking market-making obligations, providing advice, or custodian assets, should be considered a "trader" rather than a "trader," and therefore does not require registration. This position continues the legal tradition of "trader exemption" and echoes the judicial trend following the court's repeal of the "trader rule" in 2024. Wintermute emphasizes that under the current legal framework, innovation and regulation should coexist to avoid imposing undue regulatory burdens on the decentralized finance ecosystem.