CFTC staff sets expectations for 24/7 trading, clearing, and settlement

What changed

CFTC staff issued an advisory on operational, financial-resource, risk-management, surveillance, resilience, staffing, maintenance, customer-protection, and coordination obligations for continuous markets. It does not reduce existing Commodity Exchange Act or Commission requirements.

Who it affects

• DCMs, SEFs, DCOs, FCMs, clearing members, CTAs, CPOs, and clients
• Advisers allocating to continuously traded crypto derivatives

What is still open

• Firm implementation, maintenance windows, liquidity, weekend margining, and cross-market dependencies
• Whether additional Commission rules will follow

What it means for an advisor

• Diligence weekend liquidity, staffing, margin calls, outages, price sources, kill switches, clearing, and client communication
• Align portfolio monitoring and incident escalation with the venue’s actual operating schedule

Previous interpretation

Registered entities relied on general obligations without this consolidated staff advisory for continuous-market operations.