The Commodity Futures Trading Commission (CFTC) continues to explore the opportunities and challenges of around-the-clock derivatives trading and clearing, Acting Chairman Caroline D. Pham said in a keynote address at the Piper Sandler Global Exchange and Trading Conference.
Pham said that there are “no changes to CFTC regulations necessary to enable 24/7 trading,” pointing to the recent launch of continuous trading by Coinbase Derivatives, a Designated Contract Market (DCM), and Nodal Clear, a Derivatives Clearing Organization (DCO), in May 2025. She commended firms that collaborated with the CFTC over the past year, saying their efforts were “a great example of the partnership in our markets.”
Still, she acknowledged that continuous trading presents structural implications that warrant careful analysis. In April 2025, the CFTC issued a Request for Comment on the uses, benefits, and risks of 24/7 derivatives trading and clearing. “That comment period recently closed,” Pham said, “and CFTC staff are currently evaluating the many helpful responses.”
Pham emphasized that while certain derivatives already trade during low-activity periods or are held over weekends, moving fully to a 24/7 environment introduces new challenges—especially for collateral management. “Trading may be continuous, but parts of the clearing process, such as exchange of collateral, require point-in-time calculations and periodic finality while risk continues to accrue,” she explained.
One complication is that, currently, collateral exchange over weekends is not operational. As a result, central counterparties (CCPs) must rely on pre-funded collateral to mitigate credit and liquidity risk. “This raises questions about calibrating the possible exposures,” she said, pointing to the need to reevaluate concepts like the “margin period of risk” when collateral access is unavailable for more than one trading day. Pham noted that the issue is compounded if other related markets, such as spot or repo markets, are closed over the weekend. “This underscores the value and need for 24/7 spot market access to maintain a broader liquidity pool,” she added.
Beyond clearing, the transition to continuous trading impacts the entire market ecosystem. According to Pham, “24/7 trading must be evaluated holistically due to the effects not only on trading platforms and clearing houses but also on FCMs, asset managers, third-party providers, and others.” Several commenters warned that increased operational and compliance costs could be borne by all market participants—not just those engaging in weekend trading. These changes may also require renegotiating existing agreements between clients and intermediaries.
Staffing is another issue: “CCPs, exchanges, intermediaries, and asset managers may all need to operate virtually 24/7,” Pham observed. Some suggestions included trading models like 24/6 or 24/5 to allow for scheduled maintenance windows.
Weekend trading brings with it liquidity concerns, especially in low-volume periods that may see wider spreads and increased volatility. Pham addressed concerns about pricing reliability and risk management in these conditions. “Staff will need to determine whether other related markets are available to support pricing and hedging of derivatives,” she said. Some market participants fear weekend volatility could erode posted collateral, leading to auto-liquidations and the loss of hedging strategies. To mitigate this, enhanced margin requirements might be necessary—but at a cost. “Posting excess margin, potentially across multiple exchanges, may negatively impact capital efficiency,” Pham cautioned.
One potential path forward, according to Pham, could be limiting 24/7 trading to select contracts with strong customer demand. “Some products may be more appropriate for weekend trading than others,” she said. So far, the CFTC has only seen proposals related to crypto asset derivatives, which benefit from underlying spot markets that already operate continuously. “The CFTC is not aware of any plans to offer 24/7 trading beyond the crypto asset class at this time,” Pham stated, adding that more traditional commodities, like agricultural contracts, would require careful study due to the risks of illiquidity and pricing distortions.
Despite the concerns, Pham urged stakeholders to also consider the benefits of continuous markets. “Events—whether geopolitical, weather-related, or otherwise—can happen over the weekend. Forcing market participants to wait until Sunday afternoon in the U.S. to act creates risks of its own,” she said. Citing early data from Coinbase Derivatives, she reported that “weekend trading has been averaging over a thousand individual traders and hundreds of thousands of lots—similar to an average weekday.” This suggests that for markets accustomed to 24/7 activity, like crypto, extending the model to futures may be viable.
Looking ahead, Pham hinted at broader innovations in market infrastructure. The CFTC is considering how to support collateral models that are not constrained by traditional banking hours. “That might include tokenized assets, stablecoins, or other non-cash forms of margin,” she said.
Finally, Pham noted that existing regulatory language, such as definitions of a “business day,” may need updating. “We will need to identify ways to maintain the regulatory status quo for non-continuous markets while developing flexible but effective procedures for 24/7 markets,” she concluded.
As the CFTC continues to analyze market feedback and trading data, Pham affirmed the agency’s commitment to market resilience and innovation: “We must balance the risks with the benefits of progress—and always ensure the safety, integrity, and transparency of U.S. derivatives markets.”
