The CFTC has initiated a comprehensive regulatory review of 24/7 trading and clearing for derivatives markets, issuing staff guidance, requesting public comment, and staying certain product launches. Market participants including exchanges, clearinghouses, and intermediaries face new operational, risk management, and compliance considerations as continuous trading models challenge traditional settlement windows and segregation requirements. The Commission's approach emphasizes that different asset classes m
United StatesFinance and Banking
Background and Recent Developments
The prospect of 24/7 trading and clearing of regulated derivatives has attracted significant attention this year. Over the past several months, the Commodity Futures Trading Commission (“CFTC” or the “Commission”) has taken a series of actions that collectively frame the regulatory landscape under the Commodity Exchange Act (“CEA”) for market participants considering continuous operations. This alert summarizes the key developments and the issues they raise.
Staff Advisory (May 29, 2026). The CFTC’s Division of Clearing and Risk, Division of Market Oversight, and Market Participants Division jointly issued Staff Letter No. 26-16, addressed to derivatives clearing organizations (“DCOs”), designated contract markets (“DCMs”), swap execution facilities (“SEFs”), and futures commission merchants (“FCMs”). The advisory articulates staff’s views on areas of focus for entities considering a move to 24/7 trading and clearing operations. It expressly
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