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PTG Responds to Request for Input on Use of Tokenized Collateral Including Stablecoins in Derivatives Markets

Nov 26, 2025

PTG said they strongly support the CFTC's consideration of tokenized collateral, particularly payment stablecoins that meet the robust standards outlined in the GENIUS Act signed into law this year. PTG believes appropriately regulated tokenized collateral represents a transformative opportunity to enhance market efficiency, reduce settlement risks, and strengthen the global competitiveness of U.S. derivatives markets.

PTG cautioned that innovation must be balanced with prudent risk management. The Commission should establish clear criteria and redemption assurances for eligible tokenized collateral that encompasses demonstrated liquidity and price stability, robust custody frameworks, and legal certainty regarding ownership and transferability across jurisdictions.


DCOs accepting tokenized collateral must demonstrate appropriate technological infrastructure, clear procedures for handling network disruptions, adequate cybersecurity measures, and tested contingency plans. Concentration limits should treat tokenized and traditional forms of the same underlying asset consistently, preventing overreliance while allowing gradual adoption.


The future competitiveness of our markets depends on embracing technological innovation while upholding principles of safety and soundness. PTG stands ready to work collaboratively with the Commission, DCOs, and market participants to ensure successful implementation of tokenized collateral frameworks.



©2025 PTG

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