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CFTC Issues No-Action Letter on Perpetual Security Index Futures

Summarized from Press Releases

The CFTC granted relief allowing designated contract markets to convert perpetual-style broad-based security index futures into true perpetual futures.

CFTC Issues No-Action Letter on Perpetual Security Index Futures

The Commodity Futures Trading Commission issued a no-action letter providing regulatory relief to designated contract markets, or DCMs, seeking to convert existing perpetual-style broad-based security index futures contracts into true perpetual futures, according to an agency announcement.

No-action letters from the CFTC signal that agency staff will not recommend enforcement action against a party that engages in activity that might otherwise raise regulatory concerns. In this case, the relief targets a specific class of derivatives tied to broad-based security indexes structured in a perpetual format.

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The move reflects ongoing efforts by the CFTC to clarify the regulatory treatment of newer contract structures in the derivatives marketplace. Perpetual futures, which lack a fixed expiration date, have grown in prominence particularly in digital asset markets, and the agency's guidance addresses how existing products can be transitioned to conform to a true perpetual structure.

DCMs operating under CFTC oversight are required to comply with core principles governing contract design and market integrity. The no-action relief provides a pathway for exchanges to make structural changes to qualifying contracts without triggering immediate enforcement exposure during the transition period.

The full terms and conditions of the no-action relief, including any limitations on its scope, are contained in the letter itself. Continue reading at Press Releases.

Frequently Asked Questions

Q.What is a CFTC no-action letter?

A no-action letter is a statement from CFTC staff indicating they will not recommend enforcement action against a party for engaging in a specific activity that might otherwise raise regulatory concerns under the agency's rules.

Q.What are true perpetual futures and how do they differ from perpetual-style futures?

True perpetual futures are derivative contracts with no fixed expiration date, while perpetual-style futures may mimic that structure without fully conforming to it. The CFTC's letter addresses the conversion of existing perpetual-style contracts into contracts that meet the true perpetual standard.

Q.Which entities does this CFTC no-action relief apply to?

The relief applies to designated contract markets, or DCMs, that are registered with and overseen by the CFTC and are seeking to convert qualifying broad-based security index futures into true perpetual futures contracts.

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