Comment Text:
Dear Commodity Futures Trading Commission,
I strongly oppose the authorization or legitimization of perpetual derivatives in markets under your oversight. While proponents may tout these instruments as innovative or efficient, their structure poses profound risks, enabling sophisticated market participants to obscure risk and undermine financial stability.
Perpetual derivatives lack a maturity date, a design that allows institutions and hedge funds to maintain open-ended positions without ever facing settlement. This creates a mechanism for concealing losses, amplifying leverage without constraint, and distorting financial reporting. Far from enhancing markets, these instruments entrench opacity and erode transparency.
History offers clear warnings: derivatives like swaps have been exploited to defer risk and obscure accountability. Perpetual derivatives amplify this danger by eliminating the need for resolution, enabling traders to indefinitely mask toxic positions. This is not risk management—it is deliberate deception.
Permitting perpetual derivatives would not foster opportunity but expand the potential for fraud, manipulation, and systemic instability. The absence of an expiration date dismantles a critical market discipline: the obligation to settle accounts. This is not a benefit—it is a fundamental defect.
The CFTC must unequivocally reject perpetual derivatives in U.S. regulated markets. No conditions, no provisional approvals, no partial measures will suffice. Their risks are not mitigable; they are inherent. Allowing these instruments would invite exploitation by those with the means and motive to abuse them.
I urge the Commission to prohibit any proposals to authorize, list, or clear perpetual derivatives. Their introduction would undermine decades of progress toward transparency and accountability in our financial system.
Sincerely,
Ramona Doc
