Request for Information: Identifying Regulations to Facilitate Innovation and Competition to Financial Products and Services for Fintech Firms

SOFR Academy, Inc. supports the request for information by advocating for specific interpretive guidance and potential no-action relief from the CFTC. They argue that swaps referencing transaction-based benchmark credit-spread indices (like AXI or FXI) should be classified as interest-rate swaps to reduce operational uncertainty and facilitate the development of lending and hedging infrastructure.

Cboe Global Markets, Inc. supports the goals of the RFI to foster financial innovation and expand access to financial products, provided that reforms do not create regulatory arbitrage or undermine market integrity. The company argues that the Commission should distinguish between genuine innovation and efforts to circumvent established risk management and investor protection standards.

Topstep, a Chicago-based fintech firm, supports the CFTC's efforts to facilitate innovation and competition for fintech firms. They request specific regulatory guidance on integrated "super-app" interfaces, branding for affiliated entities, cross-advertising incentives, and the use of AI in derivatives markets to reduce practical barriers and uncertainty.

Coinbase supports the CFTC's request for information and advocates for a principles-based, outcomes-oriented regulatory framework that facilitates fintech innovation. They specifically argue for clarifying that onchain infrastructure and integrated firm models should be permitted where they manage risks effectively without requiring unnecessary structural separation.

The Blockchain Association (BA) supports the CFTC's effort to identify regulations that facilitate innovation for fintech firms, arguing for a technology-neutral, principles-based framework. They provide eleven specific recommendations aimed at modernizing rules for blockchain-enabled infrastructure, including a "two-rulebook" approach and clearer guidance on on-chain records and decentralized systems.

dYdX Labs, a U.S.-based Fintech firm, argues that the CFTC should streamline and adjust regulations to accommodate the unique technological features of decentralized finance (DeFi) protocols. They advocate for recognizing on-chain settlement, automated risk management, and distributed ledger records as valid substitutes for traditional regulatory requirements like mandatory clearing and recordkeeping.

CCP Global, an international association representing central counterparties, supports the CFTC's efforts to promote innovation while emphasizing that fintech firms must be subject to the same regulatory requirements as traditional entities when performing functionally equivalent activities. They argue for a "same activity, same risk, same regulatory outcome" approach to ensure market stability and prevent regulatory arbitrage, particularly regarding decentralized finance (DeFi) and derivatives clearing.

Payward, a digital asset infrastructure company, supports the CFTC's initiative to facilitate innovation and competition for fintech firms. They argue that current registration categories and compliance frameworks (specifically regarding AI agents, KYC/AML for machine counterparties, and risk disclosures) are ill-suited for modern technology and recommend specific guidance and safe harbors to accommodate these advancements.

Derivative Path Hedging Solutions, Inc., a registered CTA and fintech firm, supports the RFI's goal of identifying outdated regulations that hinder fintech innovation. They specifically argue that longstanding interpretive guidance regarding "Introducing Broker" (IB) definitions is overly broad and should be updated to exempt entities that do not provide derivatives advice or have a derivatives business line from registration requirements.

CME Group Inc. argues that while the Commission should facilitate innovation, it must not do so at the expense of risk management, market integrity, or customer protection. The commenter warns against removing regulatory "impediments" that would allow unregistered firms to conduct activities that traditionally require registration.