The CFTC Rulemaking Context
The CFTC issued an advance notice of proposed rulemaking on October 5, 2026. According to law firm Sidley, the notice outlines a proposed framework for certain retail crypto asset transactions, including Regulation Crypto Asset Transactions (Regulation CTX) and Regulation Crypto Asset Markets (Regulation CAM). The latter contemplates a new subcategory of designated contract market registration for exchanges offering only those transactions.
Liquidations are squarely within the scope of the consultation. Greenberg Traurig noted that the CFTC is seeking input on who should be allowed to provide financing, how margins should be set, what assets should qualify as collateral, and how liquidations should work.
The ANPRM is an early step, not a proposed rule. As one trade report put it, the agency is seeking public comment on a potential framework rather than setting final requirements.
Douro Labs has been an active commenter with US regulators. It previously filed with the CFTC on prediction markets and on 24/7 trading and perpetual derivatives, and in September 2026 it commented on the agency’s request on compute derivatives, according to its filing on regulations.gov.
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