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GDF Response to Commodity Futures Trading Commission (CFTC) – Crypto Sprint on President’s Working Group on Digital Asset Markets Report

GDF welcomes the opportunity to respond to the Commodity Futures Trading Commission’s (CFTC) Crypto Sprint on President’s Working Group on Digital Asset Markets Report. We strongly support the CFTC’s efforts to build a clear, proportionate and globally interoperable framework for digital asset markets. Ensuring regulatory clarity for non-security digital assets and related market activities is critical to maintaining market integrity, safeguarding investors and ensuring that the United States remains a competitive hub for innovation in the digital economy. With the right guardrails, digital assets have the potential to strengthen resilience, enhance efficiency and broaden inclusion across financial markets.

To date, as comprehensive digital asset market structure legislation is still evolving, GDF welcomes CFTC guidance and promotion of regulatory coordination. We believe the CFTC can continue to provide pragmatic compliance pathways in the absence of broader federal legislation for firms seeking to operate and innovate responsibly within the United States. This will be essential to provide legal certainty and foster confidence for institutions, entrepreneurs and consumers alike.

Our response below discusses key areas where we believe that the CFTC can deliver on the areas set out for it to deliver in the President’s Working Group on Digital Asset Markets Report on Strengthening American Leadership in Digital Financial Technology. Given the current evolution and ongoing development of market structure legislation, our responses concentrates on the key areas where the CFTC can provide guidance to the market in the absence of a Federal Framework. As such our response discusses the following key areas which correspond to recommendations for CFTC Guidance in the White House Report:

  1. Guidance to DCMs on leveraged/margined spot retail transactions;
  2. Updated rules for Commodity Pools;
  3. Collaboration with FinCEN on CIPs;
  4. Enabling of bundled custody & trading;
  5. Clarification of DeFi/DAOs registration;
  6. Guidance for FCMs on segregation;
  7. Guidance for haircuts on digital assets;
  8. Guidance on DCO acceptance of collateral;
  9. Guidance on tokenized non-cash collateral; and
  10. Guidance on blockchain recordkeeping.

Submitted 20/10/2025

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