On March 20, 2026, the Commodity Futures Trading Commission (CFTC)’s Market Participants Division (MPD) and Division of Clearing and Risk issued FAQs clarifying guidance previously provided in CFTC Staff Letters regarding the use of crypto assets as collateral in derivatives markets by certain regulated entities. This GT Alert summarizes the key takeaways.

Futures Commission Merchants (FCMs)

• FCMs relying on Staff Letter 26-05 may apply the value of a customer’s non-security crypto assets, after applicable haircuts, deposited to margin futures, foreign futures, or cleared swaps accounts to secure customer debit or deficit account balances.
• FCMs may deposit proprietary payment stablecoins as residual interest in customer…