Comment Text:
"Perpetual derivatives" are a remarkably silly idea. What are they 'derivative' of? Absolutely nothing. They are exactly identical to their underlying instrument. Lacking an expiration, they have no time value. They serve no legitimate economic purpose. Absent market manipulation, there is no reason for a 'perpetual derivative' to diverge from the current price of the underlying instrument to which they are identical. Any entity with a legitimate need for access to the underlying instrument would simply go into the 'cash' or 'spot' market or an existing well established exchange market for that product and transact there. The only conceivable purpose for 'perpetual derivatives' is to produce fees for those that create them and for those on whose platforms such products will transact. The intent is to entice transactions by those with insufficient knowledge about or access to the underlying instruments. There is no legitimate basis under the Commodity Exchange Act and the regulations thereunder for this genre of product to be approved by the Commission. 'Self-certification' of such a product would be nothing other than the manifestation of a hugely conflicted self-interest.
