On May 21, ISDA, the Securities Industry and Financial Markets Association (SIFMA) and its asset management group (SIFMA AMG) submitted a joint response to the US Commodity Futures Trading Commission’s (CFTC) request for comment on 24/7 trading and clearing. The associations believe that the feasibility of both 24/7 trading and clearing needs to be evaluated holistically, with an understanding of the interdependencies between market participants, trading venues, middleware and software providers, clearing systems, margining frameworks, payments systems, default mechanisms and adjacent markets. It is critical for the CFTC and market participants to collectively discuss and consider the full range of potential impacts, including liquidity, price transparency, collateral access and default management during non-traditional business hours. Operational and technological considerations and the costs associated with expanding trading hours to 24/7 also need to be considered. The associations welcome further engagement between the CFTC and market participants to examine these issues more closely.