Comment on CFTC-2026-1321, CFTC-2026-1321-0001, Steven, Singleton
Steven SingletonSupportOther
Summary: The commenter provides a detailed analysis supporting the Commission's objective to identify regulatory frictions for fintech firms. They propose specific opportunities to convert existing no-action letters, advisory-committee recommendations, and staff guidance into durable, generally applicable rules across various entity types.
This comment responds to RFI 2026-12337 (RIN 3038-ZA24), the Request for Information Identifying Regulations To Facilitate Innovation and Competition to Financial Products and Services for Fintech Firms, issued pursuant to Executive Order 14405. The Commission's inquiry rightly seeks to identify regulatory friction that impedes fintech partnerships with CFTC-regulated entities.
This comment supports that objective while urging that facilitating innovation and preserving the safety, soundness, and integrity protections Section II identifies are not in tension: many of the frictions documented across Futures Commission Merchants, Introducing Brokers, Swap Dealers, Commodity Pool Operators, Commodity Trading Advisors, Designated Contract Markets, Swap Execution Facilities, Derivatives Clearing Organizations, and Swap Data Repositories can be addressed by carrying forward approaches the Commission has already tested through no-action relief, advisory-committee recommendations, and staff guidance, converting them into more durable, generally applicable elements of the rule framework. Where no such precedent exists, this comment identifies where new framework content may be warranted.
The attached Exhibit A sets out, for each entity type, the documented friction points, the risk considerations any framework change should account for, and specific opportunities for Commission consideration, along with a structured summary of how these connect across the fintech ecosystem the Commission regulates.