Comment Text:
To: U.S. Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street, NW
Washington, DC 20581
United States
Re: Request for Comment on Tokenized Collateral for Derivatives Margin (Release No. 9130-25)
Date: 24th September 2025
Dear Acting Chairman Pham
Ownera welcomes the CFTC’s leadership in launching this initiative to assess the role of tokenized collateral and stablecoins in U.S. derivatives markets. We strongly support the Commission’s efforts to modernize collateral frameworks in a way that improves efficiency, reduces systemic risk, and aligns U.S. markets with global innovation.
Drawing on our experience convening and powering the Global Digital Finance (GDF) Sandbox for tokenized collateral, where Ownera’s FinP2P interoperability network connected more than 70 institutions across banks, custodians, fund managers, and technology providers, we respectfully submit the following core perspective:
Digitally native collateral recorded on the source ledger is the purest and safest form of tokenization.
Introducing unnecessary intermediaries or synthetic wrappers adds counterparty and bankruptcy risks that dilute the effectiveness of collateral.
Interoperability across ledgers and legacy systems—without centralization—ensures scalability, compliance, and adoption.
We urge the CFTC to prioritize legal clarity, operational standards, and pilot programs that enable digitally native collateral models, rather than allowing risk to migrate back into the system via intermediary-heavy structures. In addition we support the extension project work being led by ISDA and GDF to look at US counterparties.
Ownera’s Role in the GDF Sandbox
Ownera provided the interoperability layer for the GDF Tokenized Collateral Sandbox, which simulated real-world margining, substitution, repo funding, and default events across multiple distributed ledger technologies (DLTs).
Technical role: Ownera’s FinP2P protocol allowed cross-ledger settlement of tokenized money market funds (TMMFs), stablecoins, and tokenized cash in real time, without requiring a single central counterparty.
Legal & operational validation: The Sandbox demonstrated that collateral could be transferred and enforced under English and EU law
Key finding: Digitally native fund tokens—where the transfer agent’s register of ownership is maintained on-chain—proved to be the most enforceable and operationally efficient collateral instrument.
The Bankruptcy Risk of Centralized Wrappers
One of the clearest lessons from the Sandbox is that central parties dilute collateral quality.
Digital twins or SPV-backed tokens introduce new bankruptcy chains. Collateral takers become exposed not only to the fund issuer but also to the solvency and governance of the intermediary.
In insolvency, collateral may be trapped in nominee or custodian structures, undermining the fundamental principle of title transfer and settlement finality under collateral agreements.
This re-hypothecation risk is inconsistent with the objectives of derivatives margin regulation, which seeks certainty, immediacy, and enforceability.
By contrast, when ownership is recorded at the source ledger, by the regulated transfer agent, collateral takers gain direct, unmediated rights to the underlying fund units. This aligns with both market stability and investor protection.
Why Digitally Native Models Should Be the Benchmark
The CFTC’s initiative creates an opportunity to establish globally harmonized best practices. We recommend that:
Digitally native tokens, recorded at the source register, should be the reference standard for tokenized collateral eligibility.
These models deliver the closest functional equivalence to traditional title transfer.
They eliminate intermediary bankruptcy risk, ensuring collateral retains its intended credit quality.
Stablecoin collateral should be distinguished based on issuance model.
Fully reserved, regulated, and bankruptcy-remote stablecoins can serve a role in intraday liquidity.
However, wrapped, synthetic, or unregulated variants may reintroduce systemic fragility.
Interoperability, not centralization, must guide market structure.
The U.S. derivatives market spans multiple ledgers, custodians, and collateral managers.
A neutral interoperability layer (as tested in the GDF Sandbox) allows institutions to mobilize collateral across networks, while avoiding the concentration and risk of single points of failure.
Recommendations to the CFTC
We respectfully submit the following recommendations for the Commission’s consideration:
Legal Clarity: Confirm that transfers recorded on a regulated transfer agent’s on-chain register satisfy title transfer and settlement finality requirements under existing rules.
Risk Recognition: Treat digitally native fund tokens as equivalent to their non-tokenized counterparts under margin and capital frameworks, provided no intermediary risk is introduced.
Pilot Program: Launch a U.S. regulatory sandbox mirroring what is already in place for Europe/UK, that prioritizes digitally native collateral models, supported by interoperable connectivity to legacy collateral management systems.
Guardrails on Intermediaries: Ensure that wrapped, synthetic, or nominee-based structures do not qualify as “eligible collateral” unless equivalent bankruptcy protections are in place.
Conclusion
Tokenization is not simply a technical upgrade, it is an opportunity to redesign collateral markets for resilience, efficiency, and transparency.
Ownera’s work in the GDF Sandbox has shown that tokenized collateral can be deployed today in a legally enforceable, operationally viable manner. But the full benefits are only realized when collateral remains digitally native, with ownership recorded at source, and when interoperability removes silos without introducing central points of failure.
The CFTC has an historic opportunity to set this standard. We urge the Commission to recognize digitally native collateral as the benchmark model for the U.S. derivatives market.
Respectfully submitted,
Natasha Benson
COO
On behalf of Ownera
