The "Strengthening American Leadership in Digital Financial Technology" Report, published in July 2025 by the President's Working Group on Digital Asset Markets (the PWG), includes comprehensive recommendations for immediate action by the Commodity Futures Trading Commission (CFTC) and Securities and Exchange Commission (SEC).Notably, the PWG is pushing these regulators to rely on their existing rulemaking and exemptive authority–without waiting for Congress to act – to enable the trading of digital assets and "ensure that American businesses can compete internationally."
For US derivatives market participants, we'd like to draw your attention to the CFTC-specific recommendations set forth on pg. 52-57 of the Report. In particular, the PWG endorsed guidance (i) for derivatives clearinghouses to accept stablecoins and other digital assets as collateral, (ii) on the appropriate haircuts for these digital assets by intermediaries, (iii) on the adoption of tokenized non-cash collateral as regulatory margin, (iv) the applicability of various CFTC registration requirements to DeFi activities, smart contract protocols, and decentralized autonomous organizations (DAOs) (and many other issues).It caught our attention that the first item in the PWG's list of recommendations for the CFTC has already been launched, in the form of Acting Chairman Pham's "crypto sprint" and request for public input on listing spot crypto assets on CFTC-registered derivatives exchanges. We consider it likely that Acting Chairman Pham has been working closely with the White House on these issues and intends to work her way down the list.
We were also interested to see the PWG encouraging the regulatory exploration of more vertically integrated business models in the digital asset space, in order to "enhance user experience."So long as certain regulatory safeguards are in place and existing registrants aren't disadvantaged, the PWG would encourage a trend that we are already seeing in this space–so-called "one-stop shopping" for exchange trading, custody and brokerage services all in one user-friendly app.
Last, the PWG put in a plug for the House of Representatives' CLARITY Act as "an excellent foundation for digital asset market structure" in the U.S., while also encouraging Congress to consider "a handful of additional factors"–certain of which are outlined in the Report. We see this as one of many indications that the CLARITY Act will result in the CFTC as a key digital asset regulator in the US, but we expect to see many iterations of the bill before it is in final form.
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