On December 8, 2025, Commodity Futures Trading Commission (“CFTC”) Acting Chairman Caroline D. Pham announced the launch of a digital assets pilot program allowing certain digital assets to serve as collateral in U.S. futures and swaps markets. (CFTC Rel. No. 9146-25 (Dec. 8, 2025)). This announcement furthers the CFTC’s ongoing goal of advancing digital-asset innovation and promoting safe, U.S.-regulated markets as alternatives to offshore platforms and is part of the CFTC’s efforts to implement the recommendations in the President’s Working Group on Digital Asset Markets report on Strengthening American Leadership in Digital Financial Technology.
Pham framed the pilot program as part of the CFTC’s broader “crypto sprint” and described the initiative as a milestone in “America’s Golden Age of Innovation and Crypto.” The announcement by the CFTC also included new tokenized-collateral guidance for real-world assets such as U.S. Treasuries and money-market funds. It simultaneously announced the withdrawal of an outdated staff advisory made obsolete by the enactment of the GENIUS Act.
The pilot program provides a pathway for regulated futures commission merchants (“FCMs”) to accept and value digital assets as customer margin collateral. During the initial three-month period of the pilot program, eligible collateral is limited to Bitcoin (BTC), Ether (ETH), and payment stablecoins. Participating FCMs must provide weekly reporting on the total amount of digital assets held in customer accounts for each of the three digital assets currently eligible, and must promptly notify the CFTC staff of any material issues affecting digital-asset collateralization.
In parallel, the Market Participants Division (“MPD”) issued a no-action letter addressing segregation and capital requirements for FCMs that accept non-securities digital assets (including payment stablecoins) as customer margin collateral. The letter effectively sets the ground rules for the pilot program where, under this letter, FCMs can accept BTC, ETH, and payment stablecoins as customer margin and can hold payment stablecoins as part of their residual interest, provided they satisfy certain conditions, including meeting reporting and notification requirements. (CFTC Staff Ltr. No. 25-40 (Dec. 8, 2025)).
The CFTC also formally withdrew Staff Advisory No. 20-35, which had imposed earlier limitations on FCMs’ ability to accept digital assets as customer collateral. Pham emphasized that the advisory had been overtaken by developments in tokenized settlement, payment stablecoin infrastructure, and the statutory obligations created by the GENIUS Act
The tokenized-collateral guidance, released collectively by MPD, the Division of Market Oversight and the Division of Clearing and Risk alongside the pilot program, clarifies how tokenized representations of traditional financial instruments may be evaluated within the existing CFTC market regulatory framework. The CFTC emphasized the “technology-neutral” nature of its regulations and instructed market participants, including FCMs, derivatives clearing organizations and swap dealers, to analyze tokenized assets under the same legal, operational and risk-management standards that apply to their non-tokenized equivalents. (CFTC Staff Ltr. No. 25-39 (Dec. 8, 2025)).
These actions collectively represent a significant step by the CFTC toward integrating digital assets into the core infrastructure of U.S. derivatives markets. The pilot program, tokenized-collateral guidance, and withdrawal of outdated advisories mark a coordinated shift toward a regulatory model that embraces digital assets as standard components of U.S. market operations.
