CFTC issues no-action relief for DCMs converting perpetual-style digital commodity futures, expiring 30 June 2026
DCMs can convert perpetual-style digital commodity futures to true perpetuals only by meeting the letter's conditions and filing before the relief expires 30 June 2026
- — DCMs intending to convert must complete the letter's customer-protection steps — soliciting feedback from participants with open positions, giving advance notice and an opportunity to exit, and providing appropriate risk disclosures, with no other material contract terms changed — before removing expiration dates, as the relief is unavailable where these steps are not met.
- — DCMs must file the contract amendments under CFTC Regulation 40.5 or 40.6 and certify compliance with the conditions before implementing a conversion — unfiled or uncertified amendments fall outside the no-action position.
- — DCMs must complete the conditions, filing and certification before 30 June 2026 — the no-action positions expire on that date, after which conversions no longer carry the relief; with the expiry roughly two weeks out, the window to rely on it is short.
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