Ondo Finance has filed three comment letters with the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC), arguing that existing U.S. regulations alre
Ondo Finance has filed three comment letters with the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC), arguing that existing U.S. regulations already have room for products built on blockchain technology, they just need to be applied differently.
The letters, published Sep. 2, cover three separate rulemaking areas: perpetual futures product definitions, portfolio margining, and market data reporting.
Each letter addresses a different rule, but the underlying argument is the same across all three: regulators should judge whether a system works, not whether it looks like the one it's replacing.
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Perpetual futures, or "perps," are contracts that let traders bet on an asset's price without the contract ever expiring. Traditional futures use expiration dates to force prices to converge with the underlying asset.
Ondo's letter argues that perps can achieve the same convergence continuously through funding rates and mark-to-market requirements, mechanisms already compatible with existing security futures law, according to the filing.
On margining, the letter makes the case that modern infrastructure can settle exposure more frequently and measure positions in real time, meaning margin requirements should reflect a position's actual risk rather than being built around the slower settlement cycles of older systems.
On data, Ondo argues that blockchain-based transactions create a shared, verifiable record by default. Requiring a separate reporting system to reconstruct what already exists on-chain adds cost without adding accuracy, the letter says.
The filings also make a market-access case. Perpetual futures on U.S.-listed stocks currently trade almost entirely offshore.
Ondo argues that both the SEC and CFTC should actively work to bring that activity back onshore, rather than leaving it as an open question. Ondo Perps, the company's own perpetual futures product, has been live since July and is cited in the letters as a working example of the framework in practice.
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