my take: this CFTC no-action letter today is a step in the right direction, but is fairly limited in scope for defi.
it says: if you operate a frontend that is attached to a registered DCM or FCM, you will not be regulated as a broker or AP
unfortunately it doesn't cover decentralized protocols that provide onchain exchanges, non-custodial clearing, margining, settlement, liquidations, etc.
in fact, it says to rely on this relief, the frontend needs to be attached to a DCO that custodies user funds.
self-custody is the bedrock of defi, so requiring custody with regulated entities doesn't work for us