Comment on CFTC-2026-1388, CFTC-2026-1388-0001, GGBR Inc.

GGBR Inc. (“GGBR”) respectfully submits the attached comment (uploaded PDF) on the Request for Comment on the Extension of Standard Futures Contracts to 24/7 Trading and on Perpetual Contracts Referencing Physically Delivered or Storable Energy Commodities (RIN 3038-AF75). GGBR is the developer of GOLDX, a fully reserved digital-gold and perpetual-markets design. We support the responsible listing of perpetual contracts on storable commodities and respectfully urge the Commission to extend its analysis beyond energy to storable commodities generally — and in particular to precious metals, which are supported by deeper and more established price benchmarks (LBMA, COMEX) than most commodities the RFC contemplates. The attached letter explains (1) why a cash-settled gold perpetual referencing a robust, IOSCO-aligned benchmark can satisfy the DCM Core Principles; (2) why a signed, market-clearing funding rate operates as a price-convergence mechanism — not a promised yield or a bilaterally negotiated stream of payments — which supports treating a well-designed perpetual contract as a futures contract consistent with the Commission's approach as outlined in its May 2026 Policy Statement; and (3) how position limits (Part 150), SPAN2 margining, independent surveillance, and on-chain proof-of-reserves address manipulation resistance and customer protection. We respectfully request that the Commission affirm that well-designed perpetual contracts on precious metals may be listed as futures via the Regulation 40.3 process, extend any resulting guidance to storable commodities generally, and consider tailored guidance for tokenized commodities that inherit deep, established spot markets. We would welcome the opportunity to provide additional data or to participate in any Commission roundtable. The full comment is attached.