ISDA filed a comment letter on May 21, 2025 in response to the US Commodity Futures Trading Commission (CFTC) request for comment on “perpetual” style derivatives trading and clearing.
In our letter, ISDA underscores the importance of a comprehensive regulatory framework that can address the unique design and risk management features of perpetual derivatives. Drawing on its experience in the digital asset space, ISDA highlights several initiatives relevant to this discussion, including the development of standardized legal documentation through the ISDA Digital Asset Derivatives Definitions, which aim to reduce legal uncertainty and counterparty risk for OTC products referencing Bitcoin and Ether. Additionally, ISDA has explored bankruptcy risk management for digital asset markets, focusing on issues such as close-out netting and custody. The association continues to engage with global regulators on policy matters related to classification, custody, and systemic risk, and is also examining how technologies like smart contracts and distributed ledger infrastructure can support safe execution and clearing of digitally native or perpetual instruments. We welcome further engagement between the CFTC and market participants to examine these issues more closely.
The comment letter is attached.
Documents (1) for ISDA Response to CFTC Request for Comment on Trading and Clearing of “Perpetual” Style Derivatives
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