Partner Matthew Kulkin, Special Counsel Megan O'Flynn and Associate Hayley Hopkins recently authored a chapter in The Investment Lawyer on recent requests for comment made by Staff in the CFTC's Divisions of Market Oversight, Clearing and Risk, and Market Participants. The authors examine these requests, which concern the gathering of public input on emerging areas of interest in the derivatives markets, and the key questions and considerations raised by the Staff.
Excerpt: "CFTC Staff previously issued RFCs on topics such as artificial intelligence and affiliations of CFTC-registered entities. Comments for both RFCs were to be received by the CFTC on or before May 21, 2025. CFTC Staff will use the feedback 'to better inform them on the potential uses, benefits, and risks' of 24/7 trading and perpetual contracts in the derivatives markets the CFTC regulates."