[Wintermute Submits Comment Letter to SEC, Proposes Adjustments to On-Chain Settlement and DeFi Proprietary Trading Regulations] Wintermute submitted a comment letter to the SEC's Special Working Group on Crypto Assets, proposing two recommendations: 1. Allow traders to independently manage on-chain settlement processes. Wintermute argues that regulated traders conducting on-chain settlements for their own accounts should not be deemed in violation for bypassing traditional clearing institutions. As long as counterparties can independently manage their wallets and complete on-chain delivery, and traders fulfill their settlement obligations, they should be exempt from the application of the 'Customer Protection Rule.' This aims to reduce intermediaries and improve blockchain settlement efficiency. 2. Proprietary trading on DeFi should not require trader registration. Wintermute believes that engaging solely in proprietary trading on DeFi protocols (including liquidity provision) without involving client interactions, market-making obligations, advisory services, or asset custody should be classified as 'traders' rather than 'dealers,' and thus not require registration. This perspective aligns with the legal trend following the court's overturning of the 'Dealer Rule' in 2024. Wintermute emphasizes that regulations should avoid imposing undue burdens on the decentralized finance ecosystem.