
The Commodity Futures Trading Commission (CFTC) has clarified that financial intermediaries can place client funds in tokenized versions of already authorized investments and use a blockchain as a regulatory ledger, without changing the regulatory qualification of the underlying assets.
AI-generated summary
The CFTC had previously issued guidance in 2025 on tokenized collateral and a no-action letter in February 2026 regarding certain digital assets posted as collateral. The first FAQs were published on March 20, 2026.
Blockchain enters regulatory books of accounts. The Commodity Futures Trading Commission (CFTC) has updated its responses to the financial intermediaries it supervises. The regulator specifies how these companies can place client funds in tokenized versions of already authorized investments and use a blockchain to maintain certain records.
This clarification does not transform cryptocurrencies into eligible investments by default. Above all, it recognizes that an authorized asset does not necessarily lose this status when it takes the form of a token.
CFTC opens door to tokenized investments
The new answers concern in particular future commission merchants (FCM), intermediaries who receive funds and guarantees from clients on the futures markets. These sums remain separate from the company's own resources and can only be placed in a limited list of assets presenting low risks.
The CFTC now indicates that these professionals can use a tokenized version of an authorized investment. For example, it could be a US Treasury security represented by a token on a blockchain. The instrument must, however, comply with the same requirements as its traditional version and grant its holder identical or equivalent legal and economic rights.
The distinction remains important. The regulator does not allow intermediaries to freely invest their clients' money in bitcoin, ether or stablecoins. Tokenization modifies the technical support and the mode of circulation of the asset, but not its regulatory qualification.
This update extends guidance issued in 2025 on tokenized collateral and the February 2026 no-action letter regarding certain digital assets posted as collateral. The first FAQs were then published on March 20, 2026.
A blockchain can also serve as a regulatory register
The second part concerns data retention. Intermediaries registered with the CFTC must record their transactions, positions and various operational documents for specific periods of time. This information must remain accessible to controllers and be able to be reproduced quickly.
The update admits that blockchain infrastructure can perform this function. However, the technology used does not exempt the company from its obligations. The data must maintain its integrity, remain readable and be able to be communicated to the regulator in the requested format.
A blockchain can thus become the official register of an operation without requiring the establishment to maintain a main copy in a traditional database. However, relying on a distributed network still raises questions about privacy, error correction, governance and access to information.
The relevant market is already growing. According to Token Terminal, tokenized real assets represented approximately $46 billion as of September 24, 2026. Tokenized funds accounted for $34.7 billion, ahead of commodities with $7.7 billion and stocks with $3.5 billion.
AI outlook — possibilities, not facts
Financial intermediaries will begin testing tokenization solutions for traditional assets as collateral by the end of 2026.
Likely · Within months
The use of blockchain as a regulatory ledger will remain limited to pilot projects in 2026-2027 due to unresolved technical and governance challenges.
Possible · Within years

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