Comment Text:
To Whom It May Concern at the CFTC,
I appreciate the Commission’s thoughtful engagement with the evolving landscape of perpetual-style derivatives.
I encourage the CFTC not only to enable the listing and clearing of perpetual contracts in regulated markets, but also to remain open to the future role of decentralized platforms (“DEXs”) in this ecosystem.
Decentralized perpetual trading platforms operating on public blockchains offer distinct benefits that directly align with the CFTC’s core objectives of market transparency, customer protection, and systemic risk mitigation:
• Full Transparency: All trading activity, collateral, and liquidation events are verifiable on-chain in real time.
• Risk Management Innovations: Smart contracts can enforce margin calls and liquidations without human discretion, reducing latency and systemic clearinghouse risks.
• Open Access: DEXs offer a neutral trading environment free from centralized conflicts of interest.
I respectfully suggest the Commission consider frameworks that would allow registered entities to offer perpetuals via smart contract-based infrastructure, subject to appropriate audit, reporting, and risk controls.
Such an approach would encourage responsible innovation, preserve U.S. leadership in financial technology, and avoid driving the next wave of market structure offshore.
I commend the CFTC’s forward-thinking approach and look forward to seeing a regulatory environment that fosters both market integrity and technological progress.
Respectfully,
Raj Johal
