CTF Written Submission

Daniel Bruno Corvelo Costa

Nov. 27, 2025
  • The framework proposes a legally enforceable structure for using tokenized U.S. Treasury bills and GENIUS Act-compliant stablecoins as derivatives margin, with strict eligibility, custody, and redemption standards to ensure investor protection and bankruptcy remoteness.
  • It recommends a phased regulatory sandbox pilot limited to institutional participants, with conservative concentration caps, enhanced haircuts, and mandatory reporting to validate operational resilience before broader market adoption.
  • The submission calls for joint rulemaking by the CFTC and SEC to harmonize standards on tokenized collateral eligibility, valuation, and custody, reducing regulatory fragmentation and enhancing legal certainty across overlapping jurisdictions.

Last Reviewed or Updated: Nov. 28, 2025