CFTC Opens the Door to Digital Asset Collateral: Regulatory Guidance, No-Action Relief, and Practical Implications

I.  Executive Summary – On December 8, 2025, the staff of the U.S. Commodity Futures Trading Commission (“CFTC”) launched a “digital assets pilot program” (the “Digital Assets Pilot Program”) providing greater certainty to commodity derivatives market participants who wish to accept collateral in the form of certain digital assets, including Bitcoin (BTC), Ether (ETH), and existing payment stablecoins such as USDC….
By: Cadwalader, Wickersham & Taft LLP