The Commodity Futures Trading Commission (CFTC) has published a set of frequently asked questions clarifying aspects of the tokenized collateral and digital asset margin collateral framework. These were established in December 2025 via two staff guidance letters, including a Coinbase no action letter which was updated in February. Much of the FAQ confirms what was already implicit in the original letters, but two points add substantive new detail.
The most concrete addition is a specific capital charge for payment stablecoins. The no action letter required FCMs to impose “an applicable capital charge” against stablecoins deposited as residual interest in customer segregated accounts, but left the figure to be determined under each firm’s risk management program. Residual interest refers to the FCM’s own funds held in segregated customer accounts when the customer’s margin falls too low. The FAQ now specifies that the CFTC will not object if an FCM applies a 2% haircut to payment stablecoin positions, both for residual interest purposes and when computing its own regulatory capital.
The CFTC explicitly aligns this with the SEC’s treatment of broker dealer proprietary positions in payment stablecoins, citing interagency harmonization as a rationale. For bitcoin and ether, the FAQ confirms a minimum 20% capital charge for proprietary positions, consistent with the floor the no action letter had already established for those assets in certain customer account contexts.
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