WASHINGTON — The Market Participants Division of the Commodity Futures Trading Commission today announced it has issued an interpretation and a no-action position in response to a request from Coinbase Financial Markets, Inc., a registered futures commission merchant. The positions relate to CFM’s plan to offer certain digital commodity derivatives products listed on CFM’s affiliated foreign board of trade, Deribit FZE. 

The staff letter confirms that, consistent with the May 29, 2026, Order Approving KalshiEX LLC BTCPERP Futures Contract, the perpetual contracts described in the letter may be categorized as foreign futures as defined in Commission Regulation 30.1. Additionally, the letter states that, subject to certain specified conditions, MPD will not recommend the Commission take an enforcement action against CFM for posting customer-owned digital commodities and payment stablecoins with CFM’s foreign broker affiliate to margin its foreign futures and foreign options positions on CFM’s affiliate foreign board of trade under circumstances where the foreign broker has obtained a right of re-use over the customer-owned assets.