11 briefs
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
Regulatory-reporting and data teams at CFTC-reporting firms must migrate to the FDTA common identifiers and machine-readable submission formats as the joint standards take effect
The CFTC rescinded its no‑deny settlement policy and will not enforce existing no‑deny clauses, freeing defendants in CFTC enforcement matters to settle while publicly denying the allegations.
KalshiEX must operate BTCPERP under full CEA and CFTC compliance; all other DCMs must obtain separate Regulation 40.3 approval before listing any perpetual contract on assets outside the Order.
DCMs, SEFs, DCOs, and FCMs must satisfy CFTC staff expectations and conduct asset-class suitability assessments before extending operations to 24/7 trading, clearing, or settlement — proceeding without that pre-compliance creates enforcement exposure.
FCMs posting customer-owned digital commodities or stablecoins with affiliated foreign brokers as margin must satisfy MPD's specified conditions and ensure the foreign broker holds a right of re-use — transfers outside those conditions carry full enforcement exposure.
Event-contract venues need no-action letter coverage before skipping SDR reporting
France nonbank swap dealers need CFTC confirmation before using substituted compliance
Swap-clearing teams must remap CAD and MXN clearing scope before the comment window closes
Commodity pool operators cannot engage Middlebrooks or EIA All Weather Alpha Fund for CFTC-registered or client-trading activities because the consent order permanently bars trading-for-others, solicitation/acceptance of trading funds, and CFTC registration
Compliance teams at Gemini Titan, Olympus, and trading participants must operate within the no-action letter's terms to retain CFTC staff non-enforcement on swap reporting and recordkeeping
