Tokenized and Stablecoins Initiative Announced by the CFTC

Furthering its Crypto Sprint initiative, on September 23, 2025, the CFTC announced the beginning of its next Crypto Sprint initiative—this time with its sights set on tokenized collateral. The CFTC previously announced a Crypto Sprint and issued its first initiative for trading spot crypto contracts that are listed on a CFTC-registered futures exchange using its existing authority as part of implementing the recommendations in the White House digital asset report ("White House Report") that was released at the end of July. The CFTC subsequently issued a second initiative seeking public comment on the remainder of the recommendations for the CFTC that were made in the White House Report. This most recent initiative focuses upon tokenized collateral including stablecoins in derivatives markets.

With this third initiative, the CFTC seeks feedback on several matters relating to tokenized collateral that the CFTC previously raised:

• The recommendation made by the CFTC's Global Markets Advisory Committee (GMAC) in 2024 on tokenized non-cash collateral;
• CFTC observer status on industry efforts;
• Potential digital asset markets pilot programs; and
• Amendments to CFTC regulations in connection with the White House Report regarding collateral management.

2024 GMAC Recommendation

The GMAC is one of five advisory committees overseen by the CFTC that were created to provide advice and recommendations to the CFTC on a variety of regulatory and market issues affecting the integrity and competitiveness of U.S. financial markets. The advisory committees are comprised of market participants, other regulators, and academics. The GMAC focuses on the regulatory challenges of a global marketplace and makes recommendations regarding international standards for regulating the derivatives markets. The GMAC's Digital Assets Markets Subcommittee advanced a recommendation last November 2024 calling for the expansion of non-cash collateral through the use of distributed ledger technology, and provided a legal and regulatory framework for how market participants can apply existing policies, procedures, practices, and processes to support the use of distributed ledger technology for non-cash collateral in a manner consistent with margin requirements.

Digital Asset Pilot Programs

In September 2023, then-Commissioner Pham advocated for a U.S. pilot program for digital asset markets. As part of her September 2023 proposal, she called for a roundtable to engage all stakeholders, leverage the prior work of the GMAC's Digital Assets Markets Subcommittee to provide insights on the design of a successful pilot program, and then have the CFTC propose and adopt rules establishing a time-limited pilot program incorporating: registration and eligibility requirements, financial resources and other conditions, risk management, products and contract terms, and other requirements including disclosures and reporting.

Collateral Management

The White House Report called for the CFTC and SEC to take immediate action utilizing their respective rulemaking and exemptive authority to advance digital asset trading in the United States. Of the many recommendations in the White House Report, one was for the CFTC to provide guidance for derivative clearing organization (DCO) acceptance of digital asset collateral (including payment stablecoins), including DCO financial resource requirements, valuation of assets, and haircuts for margin purposes, settlement finality, treatment of digital asset custodians and self-custody, systems safeguards requirements, end-of-day reporting assets that trade 24 hours, 7 days a week, and legal considerations in areas such as netting and interests in collateral under CFTC Regulations. Additionally, the White House Report called for guidance on the adoption of tokenized non-cash collateral as regulatory margin to implement the GMAC's 2024 recommendation, as well as the review of the application of eligible depository rules to accounts holding digital assets as collateral under CFTC Regulations.

Comments on this third initiative are due by October 20, 2025, which is the same deadline for comments to the CFTC's second call for feedback on the other recommendations to the CFTC in the White House Report as well as the deadline for comments to the recently issued Advanced Notice of Proposed Rulemaking on GENIUS Act Implementation by Treasury. With the Senate Banking Committee's discussion draft of the Responsible Financial Innovation Act of 2025 and an anticipated discussion draft by the Senate Agriculture Committee expected in October, this is an opportune time for interested stakeholders to educate and provide valuable insight to Congress and the agencies in formulating a framework for regulating digital assets in the U.S.

Firms interested in submitting comments should reach out to their usual DWT contact.