Comment Text:
The International Council for Derivative Trading (ICFDT), administrator of the Certified Futures and Options Analyst (CFOA) designation, respectfully submits the attached comment letter in response to the CFTC's Request for Comment on the Direct Clearing of Derivatives by Retail Investors.
The ICFDT supports the Commission's objectives and writes to urge that the framework incorporate explicit competency standards for market professionals who serve, advise, or facilitate retail participants in direct clearing contexts. Our full submission, including specific recommendations, is contained in the attached letter.
A supporting research paper — "Credential Signaling in Derivatives Markets: A Framework for Evaluating Specialist Qualifications" (ICFDT-RP-2026-01) — is available at https://ssrn.com/abstract=6292158
Further information about the ICFDT and the CFOA program is available at www.icfdt.com
