SIFMA/SIFMA AMG Extension of Futures Trading to 24/7 RFC

Summary

SIFMA and SIFMA AMG ¹ provided comments to the Commodity Futures Trading Commission (CFTC) in response to its request for comment on the extension of standard futures contracts to 24/7 trading and on perpetual contracts referencing physically delivered or storable energy commodities (the RFC). ²

Excerpt

SIFMA supports responsible innovation in U.S. derivatives markets and recognizes that market and technological developments have increased interest, particularly from retail and crypto native market participants, in expanded trading hours for certain products. The transition from existing extended-hours trading to true 24/7 trading, however, raises material market structure, operational, liquidity, risk management, clearing, settlement, and customer protection considerations, particularly where contracts serve as benchmark risk management tools for end users or reference markets that do not trade or settle continuously.

SIFMA has previously addressed related issues in the context of the CFTC's April 2025 request for comment on trading and clearing derivatives on a 24/7 basis. In that letter, SIFMA, together with ISDA, observed that 24/7 trading must be evaluated holistically, with careful attention to the interdependencies among trading venues, clearing systems, market participants, middleware providers, payment systems, collateral processes, default management frameworks, and adjacent markets.3 Trading hours can only safely expand to the extent that the necessary clearing and risk infrastructure can support them. Those observations remain directly relevant because extended trading hours cannot be viewed in isolation from the infrastructure necessary to support continuous risk management.

SIFMA's comments below focus principally on the extension of standard futures contracts to 24/7 trading. We do not attempt to respond to each question in the RFC individually. Instead, we identify several overarching considerations that we believe should guide the Commission's analysis and any future treatment of 24/7 trading.

I. Executive Summary

SIFMA respectfully submits that any move toward 24/7 trading of standard futures contracts should be guided by the following principles:

• 24/7 trading should be evaluated holistically across the full market ecosystem. A market that trades continuously but depends on clearing, collateral, payment, settlement, surveillance, compliance, and default-management systems that do not operate continuously may relocate risk rather than reduce it.
• Weekend trading is different from existing extended-hours futures trading. Many futures contracts already trade on an extended-hours basis during the traditional trading week. The incremental question raised by 24/7 trading is the addition of weekend and holiday trading, and the reduction or elimination of established maintenance, reconciliation, and operational reset periods that support market resiliency.
• Liquidity during weekend and holiday periods should be evaluated carefully. The existence of a tradable market should not be equated with the existence of robust, resilient, and representative liquidity.
• Product-by-product review is essential. Trading conditions, liquidity profiles, commercial use cases, reference markets, and operational dependencies vary significantly across products and asset classes. The Commission should avoid a one-size-fits-all approach.
• Clearing, margin, collateral, and payment infrastructure are central to the safe operation of 24/7 trading. Robust margin collection and collateral movement during overnight, weekend, and holiday periods are essential to safe and orderly 24/7 trading, but traditional payment and funding systems do not currently operate on that basis.
• Default management protections should not be weakened. The Commission should be cautious about the introduction of models that rely on automatic liquidation or otherwise compress cure periods in ways that may undermine hedging, central clearing protections, or broader market stability.
• End users and benchmark integrity should remain central to the analysis. Standard futures contracts play a critical role in risk transfer, price discovery, and end user hedging. Changes to trading hours should be evaluated through the lens of their effects on those functions, not solely by reference to demand for continuous access.