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Evidence record

CFTC staff no-action letter lets clearing organizations use trust companies for daily settlements

Read the item · published 2026-11-05

Evidence

Confidence
High Primary source (regulator / official record); quote string-matched against the live page.
Quote verified
2026-11-07 16:56 UTC
Archived snapshot
SHA-256 1b933a73b13f081f5fc95dc9a6cfbc79eaafb883abe2c0b54a37674f9c848fcb · fetched 2026-11-07
Saved excerpt around the quote (source text, 2026-11-07)
… 7a-1(c)(2)(E) and 17 C.F.R. § 39.14. Mr. Ken McCracken Page 3 customer protection framework, Nodal argues that a trust company should also be considered acceptable to perform the daily settlement functions required by Regulation 39.14. No-Action Position Based on the facts presented and the representations Nodal has made, the Division will not recommend that the Commission take enforcement action against any DCO for using a trust company to conduct daily settlements with clearing members, if the DCO treats the trust company as if it were a settlement bank for the purpose of compliance with Regulations 39.14(c) and (d). This letter, and the position taken herein, represent the views of the Division only, and do not necessarily reflect the views of the Commission or any other division or office of the Commission. This letter, and the no-action position taken herein, …
Change log (1)
  1. 2026-11-07 Published

Verified quotes

  • “Based on the facts presented and the representations Nodal has made, the Division will not recommend that the Commission take enforcement action against any DCO for using a trust company to conduct daily settlements with clearing members, if the DCO treats the trust company as if it were a settlement bank for the purpose of compliance with Regulations 39.14(c) and (d).”
  • “Finally, Nodal represents that state-regulated trust companies are among the leading custodians of digital assets.”
  • “Nodal further states that clarifying that DCOs may use trust companies to conduct daily settlements with clearing members will facilitate the ability of DCOs to accept such assets as margin collateral by allowing them to seamlessly integrate such assets into their existing daily workflows for collateral movement.”

String-matched against https://www.cftc.gov/csl/26-30/download by our verifier before every deploy.

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