On December 12, the U.S. Commodity Futures Trading Commission (CFTC) released Release 9146-25 — a document with a long title but a very clear message: Bitcoin, Ethereum, and USDC have officially been admitted into a supervised pilot program that allows their use as collateral within the U.S. derivatives system.
This is a tightly controlled experiment, with strict requirements around oversight, reporting, custody, and risk management. Yet it marks a meaningful shift in how the CFTC envisions crypto trading in the United States: onshore, regulated, and with minimal friction between the assets investors hold and the markets they use to hedge risk.
This move coincides with another major milestone: the CFTC has also cleared the path for spot crypto products to be listed for the first time on exchanges registered under its jurisdiction.
Taken together, the direction becomes clear. Rather than pushing crypto to the fringes of the financial system, the CFTC is actively testing how digital assets can be integrated into the same infrastructure that already powers futures and swaps markets.
How Collateral Works — and Why Traders Should Care
To understand why this pilot program matters, it helps to break down collateral at its simplest level. A derivatives trade can be thought of as two parties placing a wager under the supervision of a neutral referee. Because prices can move rapidly, the referee requires both sides to post valuable assets upfront.
That asset is known as collateral, ensuring that if the market moves sharply, the trade can still be settled without chasing losses.
In practice, the “referee” is the clearinghouse. The traders are the counterparties. And the entity collecting collateral from clients is the futures commission merchant (FCM) — a highly regulated intermediary sitting between traders and the clearing system.
Historically, FCMs accepted almost exclusively U.S. dollars or U.S. Treasuries due to their stability. Crypto assets were excluded because of high volatility, complex custody requirements, and unresolved legal questions.
Release 9146-25 changes that. It outlines how tokenized assets can be used as collateral, what safeguards must be in place, and which digital assets qualify. The list is intentionally narrow: Bitcoin, Ether, and one regulated stablecoin — USDC. Crypto is being granted a supervised “backstage pass.”
What’s Inside Release 9146-25?
The document consists of two core components:
1. A digital asset collateral pilot program, and
2. A no-action letter for FCMs.
The pilot program is the centerpiece. It provides a regulatory framework for exchanges and clearinghouses to use tokenized assets — including BTC, ETH, USDC, and tokenized U.S. Treasuries — for margin and settlement.
Participants must demonstrate robust wallet controls, strong customer asset protection, accurate valuation mechanisms, and comprehensive recordkeeping. The emphasis is firmly on operational safety rather than unrestricted innovation.
The no-action letter enables enforcement in practice. It allows FCMs to accept these assets as customer collateral for a limited period under strict conditions. Importantly, it replaces earlier guidance that discouraged brokers from handling “virtual currencies” in customer segregated accounts — a stance that made sense in 2020 but has become outdated as tokenization enters mainstream finance.
Key features of the pilot include:
– Limited scope in the first three months: Only BTC, ETH, and USDC are permitted, allowing regulators to gather clean data before expanding.
– Ongoing, detailed reporting: FCMs must submit weekly reports specifying the exact amount of crypto held and where it is stored.
– Mandatory asset segregation: Crypto collateral must be held in legally enforceable, auditable segregated accounts, separate from company assets and creditors.
– Conservative haircuts: Due to higher volatility, crypto collateral is discounted relative to Treasuries.
– Time-bound testing: While no end date has been announced, similar pilots typically run one to two years to observe full market cycles.
During this period, the CFTC will collect data that previous rules could not capture: how crypto performs as collateral during calm and stressed markets, how stablecoins behave behind leveraged positions, and whether institutions can truly manage on-chain wallets at scale.
Who Is Likely to Participate First?
Several firms are already positioned to move early. Crypto.com, which operates a CFTC-registered clearinghouse, has stated that it already supports crypto and tokenized collateral in other markets and could deploy the model quickly in the U.S.
Other candidates include LedgerX, crypto-native trading firms active in CME Bitcoin futures, and FCMs that have already built institutional-grade wallet infrastructure.
Traditional brokerage firms may move more cautiously, given their limited experience with on-chain asset management. However, the incentive is clear: access to clients who want regulated trading venues without having to convert crypto into cash.
For stablecoin issuers, USDC’s inclusion sends a strong signal of regulatory alignment. Tokenized Treasury providers will also see this as an invitation — albeit one that comes with demanding custody and legal requirements.
What Changes for Traders?
The most tangible impact is in how positions are funded.
A hedge fund running a Bitcoin basis trade today might be forced to hold BTC in one place and USD at an FCM elsewhere, constantly moving capital to meet margin requirements. Under the pilot framework, that value could be held directly in BTC and posted as collateral, reducing friction and conversion costs.
For miners, instead of selling BTC to raise dollars for margin calls, they could use existing BTC holdings to back regulated futures positions. This keeps more activity onshore and reduces reliance on offshore leverage.
Retail traders are unlikely to feel immediate effects. Most retail platforms rely on FCMs and will be cautious about accepting volatile assets from smaller accounts. However, as major brokers participate and the pilot expands, options like “use your BTC balance as margin” could gradually emerge.
The Bigger Picture
For years, offshore platforms attracted U.S. traders with a simple promise: deposit crypto, use it as collateral, and trade seamlessly. Domestic exchanges couldn’t compete under the old regulatory framework, pushing liquidity beyond regulators’ visibility.
The CFTC is not trying to replicate offshore markets. Instead, it is testing whether crypto can be integrated into the U.S. system without compromising customer protection, clearinghouse stability, or market integrity.
If the experiment succeeds, the CFTC will have a blueprint for long-term integration. If it fails, the regulator retains the tools to shut it down quickly.
Release 9146-25 acknowledges a reality: these assets are already being used for leverage and hedging. Ignoring that fact only pushes risk into darker corners. This pilot brings the activity into the open, allowing the CFTC to measure, supervise, and modernize collateral mechanisms under controlled conditions.
If the coming year delivers clean data without systemic stress, U.S. traders may finally achieve what they’ve wanted since Bitcoin futures were launched: the ability to trade domestically without abandoning the assets they already hold.
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