The Commodity Futures Trading Commission (CFTC) has received inquiries from derivatives clearing organizations (DCO) or potential DCO applicants seeking to offer clearing of margined products directly to participants, such that participants would not clear through a futures commission merchant intermediary (non-intermediated model).

Currently before the CFTC is a formal request from LedgerX, LLC d.b.a. FTX US Derivatives (FTX) to amend its order of registration as a DCO to allow it to modify its existing non-intermediated model.

FTX currently operates a non-intermediated model and clears futures and options on futures contracts on a fully collateralized basis. In its request for an amended order of registration, FTX proposes to clear margined products for retail participants while continuing with a non-intermediated model.

The Commission is seeking public comment on FTX’s request, including both on specific questions and policy issues raised by use of a non-intermediated model in this manner. The questions are available here. The CFTC recommends potential commenters to review FTX documents as they are considering their comments.

Comments may be submitted electronically through the CFTC’s Comments Online process. All comments received will be posted on the CFTC website. Comments should be submitted on or before April 11, 2022.