Talos Shares Key Insights on Perpetual Derivatives in CFTC Comment Letter

At Talos, we believe that building the future of financial markets requires not just cutting-edge technology, but also constructive engagement with policymakers and regulators. That’s why we’re proud to announce that we have submitted a formal comment letter to the US Commodity Futures Trading Commission (CFTC) in response to its recent Request for Comment on the Trading and Clearing of “Perpetual” Style Derivatives.

Download the full letter from CFTC.gov

‍A collaborative approach to market integrity and innovation

Perpetual derivatives have become essential tools in global digital asset markets representing approximately 53% of the total trading volume among our international clients and offer significant benefits such as improved liquidity, continuous price discovery, and effective risk management. However, these products remain largely unavailable in the US under current regulatory frameworks. 

Our deep experience managing and supporting institutional trading in perpetual derivatives in over 30 countries has allowed us to accumulate extensive practical knowledge about market infrastructure, operational best practices, and risk mitigation strategies specific to perpetual markets.  We believe that regulators and market participants alike can benefit from these insights to gain a clear-eyed, data-driven understanding of how these products work and how they can be responsibly integrated into modern financial infrastructure.

Why engagement matters

Talos sits at the intersection of market infrastructure, institutional adoption, and regulatory evolution. By participating in initiatives like the CFTC’s public comment process, we hope to:

• Educate policymakers on the mechanics, use cases, and operational realities of digital asset markets.
  
• Share institutional insights drawn from our real-world experience, not theoretical models.
  
• Support informed policy that balances innovation, investor protection, and market integrity.
  
• Help bridge the gap between rapidly evolving global markets and the thoughtful development of US regulatory frameworks.
  

We recognize the significant responsibility that comes with operating critical market infrastructure. Our commitment extends beyond engineering, security, and client services - it also includes active participation in meaningful public discourse.

Advancing market maturity through thoughtful regulation

Perpetuals are not just another trading product; they represent a broader evolution toward always-on, globally integrated, and institutionally accessible financial markets. Ensuring these tools become available within a carefully regulated US environment benefits the long-term health and maturity of the entire financial ecosystem.

We believe that perpetual derivatives, when accompanied by the right safeguards - such as robust risk controls, transparency, and cross-market oversight - and supported by resilient infrastructure like that provided by Talos, can significantly enhance market efficiency and institutional risk management capabilities in the US.

Looking ahead

We thank the CFTC for initiating this critical dialogue and providing the opportunity for industry input. Talos remains committed to working collaboratively with regulators, policymakers, and industry peers to foster a digital asset ecosystem characterized by fairness, resilience, and responsible innovation.

Stay tuned for further updates and insights from Talos as we continue to engage and shape the future of global financial markets.