CFTC Staff Updates Crypto and Blockchain FAQs for Registrants

The U.S. Commodity Futures Trading Commission’s staff has updated its FAQs on activities involving crypto assets and blockchain technologies by registrants and registered entities.

The updates were released on September 24, 2026, by the CFTC’s Market Participants Division, Division of Market Oversight, and Division of Clearing and Risk.

The revised FAQs address two operational areas: investments of customer funds in tokenized forms of permitted investments, and the use of blockchain technology to meet recordkeeping requirements.

The action adds to the CFTC staff’s existing body of guidance on tokenized collateral and digital assets that may be accepted as margin collateral.

Scope of the updated FAQs

The CFTC staff revisions focus on the application of existing requirements to activities involving crypto assets and blockchain technology. One topic is the investment of customer funds in tokenized forms of investments that are otherwise permitted.

A second topic is whether blockchain technology can be used in connection with registrants’ recordkeeping requirements. The announcement identifies these as FAQ updates; it does not describe them as new rules.

• Customer-fund investments in tokenized forms of permitted investments
• Use of blockchain technologies for recordkeeping requirements

Connection to tokenized collateral guidance

The FAQ updates relate to earlier CFTC staff guidance on tokenized collateral. CFTC Letter No. 25-39 provided staff guidance on the use of tokenized assets as collateral in futures and swaps.

The updates also relate to CFTC Letter No. 26-05. That letter reissued a no-action position concerning futures commission merchants accepting certain digital assets and payment stablecoins as customer margin collateral, with a limited revision concerning national trust banks as permitted issuers.

Together, the materials show the agency staff addressing several distinct functions for digital and tokenized assets: collateral, customer-fund investments, and recordkeeping. The available announcement does not establish that every crypto asset or blockchain arrangement is permitted; applicability depends on the requirements addressed in the relevant guidance.

Regulatory context

The CFTC action arrives as U.S. agencies continue to address how tokenization and digital-asset activity fit within existing market frameworks. For related stablecoin policy developments, see the Federal Reserve’s request for comment on a GENIUS Act stablecoin framework.

Tokenized securities are also being considered elsewhere in the federal regulatory landscape. The SEC recently issued a conditional exemption concerning trading in tokenized NMS stocks, a separate development from the CFTC’s FAQs.

Market participants affected by the FAQ subjects may need to assess the updated staff materials alongside the earlier letters and their own applicable obligations. The CFTC announcement itself is limited to the stated FAQ topics and related prior guidance.

Continue reading: Federal Reserve’s request for comment on a GENIUS Act stablecoin framework on BTCNews.

Continue reading: conditional exemption concerning trading in tokenized NMS stocks on BTCNews.

Sources

• U.S. Commodity Futures Trading Commission: CFTC Staff Releases Updates to FAQs Concerning Registrants and Registered Entity Activities Relating to Crypto Assets and Blockchain Technologies
• U.S. Commodity Futures Trading Commission: CFTC Letter No. 25-39: Tokenized Collateral Guidance
• U.S. Commodity Futures Trading Commission: CFTC Letter No. 26-05: Staff No-Action Position Regarding Digital Assets Accepted as Margin Collateral

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