CFTC · RIN 3038-AF77

A listing is not a market.

The Board has authorized a comment on the Commission’s Request for Comment on the Listing of Compute Derivatives Contracts, 91 Fed. Reg. 54259 (August 21, 2026). Comments are due October 20, 2026.

The letter’s position: listed futures and the institutional over-the-counter book have to develop side by side. Futures open interest grows where the OTC trade clears. Power is the analogue. Compute is still reserved one bilateral transaction at a time.

What the letter asks

1. 01Do not block listed compute futures.
2. 02Judge a listing on whether the settlement series is a transaction print the Commission can inspect — not a posted offer the supplier administers.
3. 03Build, beside the listing, ISDA-documented OTC infrastructure: named reference prices, calculation-agent standards, two-way indications, and credit confirms that are not cells inside the commodity annex.
4. 04Treat an auction or dealer poll as a legitimate print when the tape is thin.
5. 05Do not treat a perpetual as the hedge for a multi-year hall or a five-year facility.

Worked term sheets are not on this site and are not attached to the public docket. Commission staff may request them. No customer names.