PANews reported on November 19 that Winternute, in its latest comment letter to the SEC's Crypto Assets Task Force, clearly stated two main arguments:

1. Allowing Self-Management of On-Chain Settlement Processes: Wintermute is urging 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 trading partners can independently manage their wallets and conduct on-chain deliveries, and the trader fulfills its obligations promptly, they should be exempt from the Customer Funds Protection Rule. This approach can significantly reduce intermediary layers and improve the efficiency of blockchain settlements.

2. Proprietary trading on DeFi does not require registration as a dealer: Wintermute 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 "dealer," and therefore registration is not required. This position continues the legal tradition of "trader exemption" and echoes the judicial trend following the court's repeal of the "dealer 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.