The CFTC has proposed a regulatory definition for "actual delivery" in crypto margin trading, stating that transferring assets to an external, non-custodial wallet within 28 days satisfies the exception from agency jurisdiction. Chairman Michael Selig indicated the rulemaking aims to codify that possession of private keys and direct control over governance or staking rights without intermediary fees constitute valid delivery for retail commodity transactions. Positions remaining as internal book-entries on exchange ledgers will continue to fall under the Commodity Exchange Act and futures contract frameworks. The proposal establishes self-custody as the definitive factor ending CFTC oversight for leveraged crypto trades, while exchange-held IOUs remain regulated. This advance notice is subject to a 60-day public comment period following Federal Register publication.