Global Digital Finance (GDF) welcomes the Commodity Futures Trading Commission’s initiative to examine the use of tokenized collateral, digital settlement assets, and regulated stablecoins in U.S. derivatives markets. As a global industry association representing firms across digital assets, tokenization, stablecoins, and market-infrastructure modernization, GDF strongly supports the CFTC’s continued leadership in this area.
GDF agrees that tokenization offers a material opportunity to strengthen the safety, efficiency, and resilience of collateral management. Tokenized money-market funds, Treasuries, and GENIUS-compliant payment stablecoins can enhance collateral mobility, support real-time or atomic settlement, reduce operational frictions, and improve transparency across margining and settlement workflows. The themes of collateral efficiency, stablecoin eligibility, legal certainty, operational resilience, and international regulatory consistency are all explored in more detail throughout our response.
We also welcome the CFTC’s commitment to aligning its work with the GMAC Digital Asset Markets Subcommittee recommendations, which recognize that DLT-based collateral can reduce settlement risk, expand the pool of eligible non-cash assets, and streamline cross-border liquidity flows. Further, the industry continues to advocate for proportionate and risk-sensitive prudential treatment of tokenized assets and stablecoins, an approach reflected in the recent multisectoral letter to the Basel Committee on Banking Supervision, to which GDF was a co-signatory. Ensuring coherence between derivatives regulation and prudential frameworks will be essential to preventing bifurcation of collateral markets and enabling regulated intermediaries to participate safely in digital-asset ecosystems.
Submitted: 26/11/25