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Two stacks. One future: agentic payments on the internet.

The CFTC just told self-custodial wallet developers they don't need to register as brokers. Phantom Wallet received a no-action letter stating the CFTC will not pursue enforcement against self-custodial wallet developers who connect users to regulated trading venues, as long as they don't custody user funds. First time the agency has formally drawn that line. Here's why this is massive: Under existing U.S. law, any entity that solicits or facilitates derivatives trading typically must register as an introducing broker with the CFTC. That rule was written for traditional finance intermediaries. But as self-custodial wallets started integrating access to derivatives markets, developers faced a legal gray area that could have classified them as unregistered brokers simply for writing software. The CFTC's position was, if your wallet software connects users to properly registered futures commission merchants, introducing brokers, or designated contract markets, and you don't custody user funds, you are not a broker. You're a software provider. The timing is not coincidental. One week ago, CFTC Chairman Mike Selig said at FIA's Boca Raton conference, "For too long, there has been an open question as to whether software providers trigger the CFTC's registration requirements. We intend to address this question head-on." Seven days later, they did. This matters far beyond Phantom. Every self-custodial wallet developer and every open-source protocol interface that connects users to regulated markets now has a reference point. Write software, don't custody funds, route through registered intermediaries, and the CFTC will not come after you. For context, the previous administration used ambiguous intermediary rules as a weapon against developers. Tornado Cash developers were prosecuted. Frontends shut down preemptively. The chilling effect pushed builders offshore. This no-action letter, combined with Selig ending "the days of CFTC-SEC infighting" through Project Crypto, signals a complete reversal. The U.S. is actively trying to bring developers back.

Since the market crash on October 11 — for reasons everyone in the industry understands — we’ve seen some institutions take hits, some people exit the space, and some competitors quietly stop promoting their “XX Life Meme” tokens. Many friends have asked me whether this means a bear market is coming. I don’t have that answer — but there’s a more important question you should be asking yourself: Do you still believe in the future of Bitcoin and the crypto industry? If your answer is no, then perhaps this is the right moment to step away. But if your answer is yes, then even if a bear market is approaching, this is actually the best time to build — to create real value for users and position yourself for the next wave of growth. Bear markets test conviction. Builders use them to prepare for the next bull run.

Here’s a controversial take on the future of ZK. Ready? In short, for any given project, ZKVMs will fade, and custom ZK will take over. Here's why: ZKVMs have been crucial for widespread adoption by significantly reducing time to market. However, this comes at the cost of high resource demand for proof generation. While this cost is decreasing, custom ZK is likely to be more performant. Consider an application's evolution. It starts with ZKVM, finds PMF, achieves success, and then aims to improve its performance. Transitioning from ZKVM to custom ZK becomes an obvious choice, as time-to-market is no longer an issue. Now, to be clear, this doesn't diminish the value addition of ZKVMs at all. I think they will forever be essential, but as a bootstrap mechanism for any new project. Feel free to challenge it!