The CFTC’s tokenized collateral pilot provides a broad framework for accepting tokenized Treasuries and money market funds as margin, but leaves specific standards to be developed. The December 8 launch included an unanticipated element: same day approval of Coinbase’s detailed no-action request for accepting crypto assets (bitcoin and ether) and stablecoins as customer collateral. The result is a bifurcated approach – traditional firms face principles-based guidance requiring individualized analysis, while crypto firms have 18 pages of specific rules.
The contrast is notable given industry expectations. When Acting CFTC Chair Caroline Pham announced the tokenized collateral initiative in September, the CFTC received over 40 comment letters during the public comment period, many requesting detailed implementation guidance.
The seven page staff guidance establishes that tokenized assets should generally be treated like their underlying assets, with existing regulations applying. However, it defers specifics on key operational questions.
The CFTC’s Global Markets Advisory Committee submitted detailed recommendations in November 2024 requesting specific haircut methodologies for different tokenization structures, custody standards for distributed ledger platforms, and frameworks for analyzing legal enforceability. ISDA similarly sought guidance on how settlement time differences should affect haircuts and which DLT custodians would qualify as eligible depositories.
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