Thank you to Walt and the entire FIA team for inviting me here to speak at FIA EXPO. It is an honor to have set out my agenda as Acting Chairman earlier this year at FIA BOCA, and to now share with you today the incredible progress that the CFTC has made to date, and what’s still to come. It’s been an honor to usher in a new era of innovation and market structure under my leadership since January, from perpetual-style futures, 24/7 and extended hours trading, prediction markets, and the CFTC’s Crypto Sprint.
When we look back at the inflection points that re-shaped global finance, certain patterns become unmistakable. In the 1970s and 1980s, the electronification of securities markets transformed the very architecture of price discovery, market access, and risk management. What began as incremental automation evolved into a wholesale rethinking of how markets operate—driving efficiency, transparency, and resilience on a scale that was unimaginable at the outset.
Today, we stand before a parallel moment. Blockchain technology and the tokenization of financial instruments are not merely new tools; they represent a structural modernization of the market’s underlying infrastructure. Just as electronic trading shifted us from paper tickets to integrated, data-rich environments, distributed ledgers shift us from siloed recordkeeping to shared, programmable, and verifiable systems of value.
The same core principles that guided prior waves of innovation—market integrity, customer protection, and sound risk governance—must anchor us now. But we should also recognize that transformational technologies rarely arrive fully formed. They mature through responsible experimentation, robust public-private collaboration, and clear, forward-looking regulatory frameworks.
If we approach blockchain and tokenization with the same pragmatism, curiosity, and commitment to fairness that guided earlier eras of modernization, we can unlock the efficiencies of digital assets while preserving the trust that underpins our markets. This is our opportunity to shape the next chapter of financial evolution—one that builds on history rather than repeating it, and one that ensures U.S. markets remain a global benchmark for innovation and integrity.
What a difference a year makes. Last November, the Digital Asset Markets Subcommittee (DAMS) of the CFTC’s Global Markets Advisory Committee (GMAC), which I sponsor, had just released its first recommendations on tokenization of non-cash collateral. The report made the case that tokenization is “simply another technological wrapper for existing assets,” and that modern plumbing can remove frictions that hinder collateral mobility and efficiency.
A year later, as more of the world moves to 24/7 markets in asset classes with sufficient liquidity, those initial findings are more relevant than ever. Blockchains have proven their utility and durability as constantly upgradable financial market infrastructure, which presents a tremendous opportunity to improve the old ways of managing collateral.
Today, I’ll tell you what the CFTC has accomplished since May 2025, and outline the CFTC’s 12-month Crypto Sprint—listed spot crypto trading, tokenized collateral including stablecoins, and technical amendments to our regulations to enable the use of blockchain technology and market infrastructure.
Continuing to Deliver Results
I want to highlight some of the key accomplishments that the CFTC has achieved since our first 100 days, in addition to our day-to-day work. I thank my directors and their staff who have been working so hard all year to deliver these results. Most of these initiatives address proposals or concerns I raised as a Commissioner, and some address longstanding issues created by overreach in the CFTC’s implementation of the Dodd-Frank Act. I am also very pleased that the CFTC has continued to adopt recommendations from the CFTC’s GMAC.
Since May 2025, the CFTC has completed the following:
Swaps Market and Reducing Regulatory Burdens
- Issued staff interpretative letter regarding certain cross-border definitions to provide clarity and reaffirm the CFTC’s longstanding application of foreign futures and options and cross-border swaps regulation
- Issued staff procedures to provide clarity on treatment of non-compliance issues and enforcement for non-U.S. swap entities relying on substituted compliance
- Issued proposed rules to amend swap dealer external business conduct and swap documentation requirements
- Issued no-action letter on swap data error correction notification requirements
- Issued no-action letter on SEF order book requirements
- Withdrew proposed rules on parts 37 and 38 of CFTC regulations
- Withdrew proposed rules on operational resilience framework
- Withdrew staff guidance on listing voluntary carbon credit derivatives contracts
- Withdrew staff guidance on derivatives clearing organization (DCO) recovery plans and wind-down plans
- Withdrew staff advisory on prime brokerage arrangements
Innovation and Market Structure
- Issued staff advisory on foreign board of trade (FBOT) registration to provide clarity for non-U.S. exchanges seeking to provide direct access to U.S. participants, regardless of asset class
- Issued staff advisory on market volatility controls
- Issued staff advisory on risk management and compliance requirements for designated contract markets (DCMs), DCOs, futures commission merchants (FCMs), and introducing brokers (IBs), including sports-related event contracts
- Issued staff FAQs on FCM registration and compliance given the number of non-traditional entities and new entrants in our derivatives markets
- Announced implementation of Nasdaq Market Surveillance System to improve the CFTC’s market oversight tools
- Hosted first joint roundtable with SEC in 15 years to discuss innovation, market structure, and harmonization
Golden Age of Crypto
The American story is one of innovation. From the great transcontinental railroads, to the internet worldwide, American entrepreneurs have held high a shining beacon to the future. The President’s Working Group on Digital Asset Markets, established by President Trump’s executive order in the first days of the Administration, recognizes our American spirit of innovation and endorses the notion that digital assets and blockchain technologies can revolutionize not just America’s financial system, but systems of ownership and governance economy-wide.
The President’s Working Group is ushering in the Golden Age of Crypto and published its report, Strengthening American Leadership in Digital Financial Technology, with a comprehensive set of recommendations to provide regulatory clarity and adopt a pro-innovation mindset towards digital assets and blockchain technologies.
The report addresses key areas such as:
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Positioning America as the leader in digital asset markets
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Modernizing bank regulation for digital assets
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Strengthening the role of the U.S. dollar
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Combating illicit finance in the Digital Age
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Ensuring fairness and predictability in digital asset taxation
For too long, a lack of clarity and destructive regulation-by-enforcement policy has held back U.S. businesses and entrepreneurs whilst the rest of the world established frameworks for digital assets and crypto to facilitate innovation in their jurisdictions. Indeed, many U.S. innovators were driven offshore to jurisdictions with more regulatory clarity, such as in Asia, Europe, and the Middle East. That is why the U.S. cannot delay in moving forward to welcome back home Americans and others that want to invest, hire, and build in the United States of America.
Accordingly, with respect to digital asset markets, the President’s Working Group report recommends that the SEC and CFTC use their existing authorities to (1) immediately enable the trading of digital assets at the Federal level by providing clarity to market participants on issues such as registration, custody, trading, and recordkeeping; and (2) allow innovative financial products to reach consumers without bureaucratic delays through the use of tools like safe harbors and regulatory sandboxes.
The report lauds Congressional efforts such as the historic enactment of the GENIUS Act to establish the first-ever Federal regulatory framework for stablecoins, and the passage by the House of Representatives of the groundbreaking CLARITY Act and other legislative proposals on digital asset market structure, including ongoing progress by the Senate Agriculture Committee and the Senate Banking Committee. Meanwhile Congress continues this important work, the U.S. market regulators are answering the President’s call to act now with two complementary initiatives to continue the swift progress on providing regulatory clarity: the SEC’s Project Crypto and the CFTC’s Crypto Sprint. Our goal is clear: for the United States to lead in responsible innovation and safe modernization, and not just talk about it.
Golden Age of Market Innovation
Together, the SEC and the CFTC have embarked on a new beginning for coordination between our agencies. We will work together to harness our Nation’s unique regulatory structure into a source of strength for market participants, investors, and all Americans. To the extent possible and appropriate in the public interest under existing statutes, our agencies will consider harmonizing product and venue definitions; streamlining reporting and data standards; aligning capital and margin frameworks; and standing up coordinated innovation exemptions using existing authority.
On September 29, SEC Chairman Paul S. Atkins and I hosted, for the first time in 15 years, a joint SEC-CFTC roundtable to discuss regulatory harmonization that will enable increased market choice and protect investors through clear, predictable, and pro-innovation regulatory frameworks that addresses, among other topics, innovation exemptions and DeFi.
I’ll say it again: the turf war is over. We are getting back to basics and back to regular order.
CFTC Crypto Sprint
In August, I announced the CFTC’s 12-month Crypto Sprint to implement the President’s Working Group recommendations. I have long advocated that simplicity is the solution, and that the U.S. must have a durable and flexible approach to regulation that will keep up with continuing innovation and stand the test of time. I have cautioned that we must take to heart the lessons learned from the Dodd-Frank Act, which had unintended consequences such as creating regulatory moats and market fragmentation.
This means relying upon technology-neutral regulations that do not have to be continually rewritten to keep up with innovation, and activity-based regulations that do not require burdensome and costly entity-registration requirements that stifle competition by raising the gate to new entrants with less capital like start-ups and entrepreneurs.
Right after the release of the President’s Working Group report, the SEC and CFTC outlined our near-term initiatives. As part of our Crypto Sprint, the CFTC launched public consultations on listed spot crypto trading and all other President’s Working Group report recommendations.
The CFTC’s Crypto Sprint has three main components: (1) listed spot crypto trading, which will be live on a DCM by the end of the year; (2) enabling tokenized collateral, including stablecoins, in derivatives markets, with guidance expected by the end of the year and DCOs going live by Q1 or Q2 of next year; and (3) a rulemaking to make technical amendments to the CFTC’s regulations for collateral, margin, clearing, settlement, reporting, and recordkeeping to enable the use of blockchain technology and market infrastructure including tokenization in our markets. The rulemaking is expected to begin next year and be completed by August 2026.
That will complete the CFTC’s 12-month Crypto Sprint to implement the President’s Working Group report recommendations.
Listed Spot Crypto Trading
The SEC and CFTC released a joint staff statement in September that current U.S. law does not prohibit SEC- or CFTC-registered exchanges from facilitating trading of certain spot crypto asset products. In other words, we are bringing digital assets and crypto inside our existing regulatory perimeter for securities and futures exchanges, which has provided unmatched access, market integrity, and investor protection for nearly 100 years.
U.S. capital markets are the deepest and most liquid in the world, and we will use that strength now.
Listed spot crypto trading on DCMs is permissible under the Commodity Exchange Act, pursuant to amendments made by the Dodd-Frank Act, for retail commodity transactions involving leverage, margin, or financing. One type of trade workflow could resemble cash equities, where an FCM provides leverage similar to a prime broker, the DCM is the execution venue, and the DCO performs post-trade processing. This framework may be especially appealing to institutional liquidity providers and other market participants, because it utilizes existing regulations and processes for futures and options trading; will simplify implementation of operational, risk management, and compliance requirements; and will have best-in-class customer protections and market integrity.
Cross-Border Framework
Throughout my term and my sponsorship of the CFTC’s GMAC, I have been a staunch advocate for access to markets. Drawing upon the lessons learned from Dodd-Frank, it has been a priority for me to ensure that there is a pragmatic cross-border framework, including substituted compliance, mutual recognition, and passporting as appropriate, in order to avoid market fragmentation. That is why I believe that, in the near term, we should use our existing registration categories for brokers, dealers, exchanges, and other market participants because the CFTC’s cross-border approach to foreign markets, products, and intermediaries has been in place for decades.
We should not have to reinvent the wheel.
Two months ago, the CFTC released an advisory to reaffirm our longstanding framework for the registration and recognition of non-U.S. exchanges or FBOTs, which dates back to the 1990s. By using this framework to provide regulatory clarity for non-U.S. exchanges, whether traditional or digital asset markets, that are in jurisdictions with comparable regulatory regimes to the U.S., this is the fastest way that we can legally onshore trading activity efficiently and safely under CFTC regulations and open up U.S. markets to the rest of the world.
Because of the lack of U.S. regulatory clarity and the enforcement-first approach of the past several years, many U.S. firms established affiliates in non-U.S. jurisdictions with clear regulations for crypto asset activities. For example, these U.S. firms may have an EU crypto derivatives trading venue that is authorized under the Markets in Financial Instruments Directive (MiFID) regime as a regulated market (RM) or multilateral trading facility (MTF). These EU trading venues could seek to provide access to U.S. market participants under the CFTC’s regulatory frameworks for FBOTs or exempt swap execution facilities (SEFs), as appropriate.
The CFTC will also explore whether trading platforms authorized under the EU Markets in Crypto-Assets Regulation (MiCA), or similar virtual asset or crypto asset regimes, would also qualify under the CFTC’s current cross-border frameworks. Because so many foreign jurisdictions, in the vacuum over the past several years of a coherent U.S. digital asset policy, have implemented regulatory regimes that are not technology neutral, but are instead specific to crypto and blockchain technology, I believe it is critical for the U.S. to evaluate the most pragmatic path forward, particularly because those non-U.S. crypto asset regimes already include pillars such as capital, risk management, market conduct, retail protection, custody, conflicts of interest, transparency, and illicit finance.
Tokenized Collateral Including Stablecoins
In September, the CFTC launched an initiative for the use of tokenized collateral including stablecoins in derivatives markets, with a public comment period that ends this month. This initiative builds on the CFTC’s successful Crypto CEO Forum held in February 2025 and puts into practice the recommendations from the GMAC’s DAMS and the President’s Working Group report, directing the CFTC to provide guidance on the adoption of tokenized cash and non-cash collateral as regulatory margin.
At our historic Crypto CEO Forum, we discussed how innovation and blockchain technology will drive progress in derivatives markets, especially for modernization of collateral management and greater capital efficiency. These market improvements will unleash U.S. economic growth because market participants can put their dollars to work smarter and go further.
The public has spoken: tokenized markets are here, and they are the future. For years I have said that collateral management is the “killer app” for stablecoins in markets. The CFTC continues to move full speed ahead at the cutting edge of responsible innovation, and I appreciate the support of our industry partners.
Our markets are global and increasingly 24/7, but bank rails are not. That mismatch creates avoidable settlement risk and unnecessary drag on capital. The GMAC’s work last year documented the operational bottlenecks of today’s non-cash collateral—sequential intermediaries, limits on secondary transfers, lack of 24/7/365 capabilities—and points to blockchain as a means to deliver real-time collateral mobility without changing the character of the asset itself.
Now, the CFTC is taking a concrete step toward enabling real-time collateral mobility, improving capital efficiency, and hard-wiring resiliency into U.S. clearing and settlement infrastructure. By working side-by-side with market participants, clearinghouses, and prudential regulators, the CFTC is helping operationalize what we’ve been talking about for years: moving from pilots and proofs-of-concept to the supervised use of tokenized collateral within our existing regulatory framework. Important issues like convertibility, liquidity, transparency, custody safeguards, and haircuts should be addressed, so everyone knows the rules of the road.
Tokenized money market funds
The CFTC sees tokenized money market funds, or TMMFs, as a fast-follower use case building directly on the same risk framework.
Money market funds already play a central role in derivatives margin today. The GMAC’s prior margin-rule recommendations paved the way by calling on the CFTC to remove outdated restrictions on MMFs engaged in repo and securities lending.
Tokenization simply modernizes how those MMFs are recorded and transferred. It turns daily NAV shares into onchain instruments that can move 24/7 between eligible custodians and clearing members.
Here’s how this could work:
- Eligible assets: TMMFs would remain regulated under Rule 2a-7 and maintain all existing liquidity, maturity, and credit-quality standards.
- Custody and control: DCOs and FCMs would hold perfected control over the tokenized share—not the underlying portfolio—consistent with how we treat tokenized cash under GENIUS.
- Haircuts and valuation: TMMF tokens would be haircut using the same risk-based approach already applied to MMFs under Part 39, adjusted for any settlement-time differences.
- Liquidity resource qualification: Because TMMFs settle in U.S. dollars and are redeemable on demand through regulated intermediaries, DCOs may count them as qualifying liquidity resources under § 39.33(c)(3).
- Interoperability: With both payment stablecoins and TMMFs tokenized to common standards, clearing members could seamlessly move collateral between cash-like and yield-bearing positions, improving resiliency, and capital efficiency.
As I’ve said before: embracing new technology does not mean compromising on market integrity—it means using technology to achieve the same protections faster, cheaper, and better.
Qualified payment stablecoins
Congress has now drawn bright lines: payment stablecoins that meet strict prudential standards—dollar-denominated, non-yield-bearing, 1:1 redeemable, backed by high-quality liquid reserves, and issued by appropriately supervised U.S. entities—are money-like instruments. That is exactly the class of tokens we’re talking about as collateral and settlement assets.
Important questions will need to be addressed regarding whether our rules should treat these qualified payment stablecoins as cash or cash equivalents, as commenters highlight their stable value, high liquidity, and ready convertibility. For VM, that means considering whether haircuts are appropriate. For IM, I believe that an interim “look-through” approach tied to disclosed reserve assets is a practical bridge while the market scales. In times of market stress, it may be necessary to consider whether a Fed facility for stablecoins is appropriate to address liquidity and other concerns.
Specifically, the GENIUS Act implicates CFTC regulations in certain key areas. Section 3(g) states that payment stablecoins that are not issued by a permitted issuer cannot be used as cash or as cash equivalent margin or collateral for FCMs, DCOs, or swap dealers. Section 10 states that CFTC registrants (such as FCMs and swap dealers) can provide custodial or safekeeping services with respect to payment stablecoins, including that Section 10(b) requirements can be superseded by similar CFTC requirements. The CFTC welcomes public comments on these GENIUS Act provisions as part of the CFTC’s Crypto Sprint.
Part 39 and DCO initiatives
Some DCOs have announced initiatives to use stablecoins as collateral. In order to advance regulatory clarity and implement the GENIUS Act, I encourage DCOs and their clearing members to consider, under existing Part 39, whether qualified payment stablecoins are:
- Eligible margin and settlement assets
- Acceptable as initial margin
- Qualifying liquidity resources and
- Unencumbered liquid financial assets
Equally important, I want to acknowledge questions about perfected security interest. To comply with Part 39, a perfected security interest with respect to stablecoins should be addressed. I believe that seeking a lien over the issuer’s underlying reserve assets may conflict with the purposes of the GENIUS Act, which treats the payment stablecoin itself as the settlement asset.
Further, I believe that we should avoid double-counting of liquidity resources, which is consistent with the Principles for Financial Market Infrastructures (PFMI) on settlement assets. Once the CFTC issues its tokenized collateral guidance, bodies such as the Committee on Payments and Market Infrastructure and the International Organization of Securities Commissions (CPMI-IOSCO) may want to consider whether international standard setting is appropriate to prevent market fragmentation, mitigate systemic risk, and ensure financial stability.
Other steps
In addition, the CFTC will consider whether relief is appropriate to:
- Add qualified payment stablecoins to the eligible collateral list for swap entities
- Recognize qualified payment stablecoins for certain purposes for VM, and
- Permit DCOs and FCMs to invest customer funds in them, with appropriate limits on concentration, custody, and convertibility.
Conclusion
As we chart this next stage of market modernization, we should remember that every major advance in finance has been propelled by a simple belief: that with integrity, collaboration, and discipline, we can build systems that serve people better than the ones that came before. The electronification of past decades did not diminish our markets—it elevated them, expanding opportunity while strengthening resilience. Blockchain and tokenization offer us a similar horizon today. If we meet this moment with the same professionalism and commitment to the public interest, we can shape a future where our markets are not only efficient with more access, but also more transparent, more competitive, and more innovative. That’s the job, and that’s what we will achieve together.
Thank you.