Ondo Finance submits comment letters to the SEC and CFTC
Ondo Finance has submitted three comment letters to the U.S. Securities and Exchange Commission (SEC) and the U.S. Commodity Futures Trading Commission (CFTC), arguing that existing U.S. regulations already leave room for products based on blockchain technology and only need to be applied in different ways.
The letters were released on September 2 and covered three different areas of rule-making: perpetual futures product definition, portfolio margins, and market data reporting. Each letter addresses a different rule, but the core theory is the same: regulators should judge whether a system is working effectively, not whether it looks similar to the one being replaced.
Old convention, new infrastructure
Perpetual futures (or "perpetual contracts") are trading instruments that allow traders to make bets on asset prices without contracts that never expire. Traditional futures force the price to converge with the underlying asset through the maturity date. Ondo's letter points out that perpetual contracts can continue to achieve the same convergence effect through funding rates and mark-to-market requirements-mechanisms that are already compatible with existing securities and futures laws.
Regarding margins, the letter argued that modern infrastructure can settle risk exposures more frequently and measure positions in real time, so margin requirements should reflect the actual risk of positions rather than be built around the slower settlement cycles of the old system.
When it comes to data, Ondo believes that blockchain-based transactions create shared and verifiable records by default. Requiring an independent reporting system to reconstruct information already on the chain will only increase costs rather than improve accuracy.
Competitive arguments, not just technical arguments
These documents also provide market access reasons. Perpetual futures on U.S. listed stocks are currently traded almost entirely offshore. Ondo believes that the SEC and CFTC should actively push the business back to home rather than make it an open issue.
Ondo Perps, the company's own perpetual futures product, has been cited in letters as an example of the actual operation of the framework since its launch in July.

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