Introduction:
On October 5, 2026, the Commodity Futures Trading Commission (“CFTC”) issued an Advanced Notice of Proposed Rulemaking (“ANPRM”1) regarding its intent to establish a comprehensive regulatory framework for retail commodity transactions involving crypto assets (“CTXs”) and the exchanges that offer trading in CTXs, which the CFTC calls crypto asset markets (“CAMs”).2
While the ANPRM does not include actual rule text – that would follow in a proposed rulemaking – the ANPRM contains two proposed frameworks: (i) Regulation CTX, which would establish when crypto asset transactions fall under the CFTC’s jurisdiction; and (ii) Regulation CAM which would establish a new CFTC-regulated framework…
