The United States has signaled a clear distinction between crypto assets suitable for trading and those best suited for use as collateral in the derivatives markets.
On Dec 8, the Commodity Futures Trading Commission (CFTC) authorized Futures Commission Merchants (FCMs) to accept Bitcoin, Ethereum, and USDC as eligible margin under a digital assets pilot program.
The move brings these tokens into the operational framework used for futures and swaps clearing, placing them alongside more traditional forms of performance bond, like Treasury Bills and gold, subject to risk-based adjustments.
Acting Chair Caroline Pham described the initiative as part of an effort to ensure that crypto-linked leverage sits within US bankruptcy protections, segregation rules, and continuous monitoring, rather than in offshore environments.
According to her:
“This imperative has never been more important given recent customer losses on non-US crypto exchanges.”
The Safe Harbor strategy
The pilot aims to give institutional traders the option to collateralize positions with assets cleared under US oversight, rather than relying on liquidation engines operated by offshore exchanges.
Under the new regime, BTC, ETH, and USDC can be posted as margin, subject to frequent reporting, custody requirements, and valuation “haircuts” designed to account for volatility and operational risk.
For policymakers, the approach is intended to create a domestic alternative to high-volume offshore trading venues while retaining the CFTC’s longstanding safeguards for leveraged derivatives activity.
The program also establishes a framework for assessing tokenized collateral in practice, giving regulators visibility into how digital assets perform within a system built for continuous margin calls and intraday risk checks.
Heath Tarbert, President of Circle, said:
“Deploying prudentially supervised payment stablecoins across CFTC-regulated markets protects customers, reduces settlement frictions, supports 24/7 risk reduction, and advances US dollar leadership through global regulatory interoperability. Enabling near-real-time margin settlement will also mitigate settlement-failure and liquidity-squeeze risks across evenings, weekends, and holidays.
XRP, Solana, and Cardano are missing
The pilot’s limited asset set immediately drew attention to what was not included.
Despite regulatory momentum in 2025, crypto assets such as Solana, XRP, and Ripple’s RLUSD stablecoin were excluded from the first tranche.
Market participants said the decision likely reflects a conservative approach to liquidity depth, volatility, and valuation ease during periods of stress.
For context, analysts noted that XRP’s regulatory profile has evolved significantly over the past year, yet its eligibility as collateral would require a higher threshold. This is because collateral frameworks favor assets that can be valued reliably and liquidated without disrupting markets.
However, XRP’s domestic liquidity, while significant, is materially lower than BTC and ETH, which likely factored into the program’s early asset selection.
Moreover, the absence of RLUSD generated a similar discussion.
While Ripple’s payment stablecoin is gaining traction and was recently included in Singapore’s expanded MPI licensing for cross-border services, its domestic footprint remains small compared with USDC.
As a result, the CFTC may have opted to begin with the stablecoin that currently serves as the primary regulated dollar proxy in US on-chain markets.
Still, Ripple leadership has publicly embraced the pilot as a victory for the broader crypto industry.
Jack McDonald, SVP of Stablecoins at Ripple, said:
“By recognizing tokenized digital assets—including stablecoins—as eligible margin, the CFTC is providing the regulatory clarity needed to move the industry forward. This step will unlock greater capital efficiency and solidify US leadership in financial innovation. At Ripple, we look forward to continuing to partner with the CFTC and the industry to ensure the safe and responsible scaling of digital assets.”
The tone of this response suggests Ripple views the pilot not as a closed door, but as a “proof of concept” phase.
By validating the mechanism of tokenized collateral using USDC, the CFTC is building the rails that other stablecoins, like RLUSD, could eventually ride once they meet the requisite liquidity thresholds.
Meanwhile, the CFTC did not comment directly on the rationale for specific exclusions. However, the narrow list aligns with the pilot’s stated objective of assessing tokenized collateral through a tightly controlled set of assets before considering broader expansion.
A new landscape
The CFTC’s pilot provides the United States with a defined mechanism to test tokenized collateral within its derivatives clearing architecture.
It also establishes the first contours of a regulatory hierarchy: some assets can be traded under supervision, while fewer still can serve as collateral for margining.
For the industry, the pilot is both a milestone and a constraint. It brings digital assets closer to the core of US financial infrastructure while also clarifying the standards required to achieve that level of depth, stability, custody readiness, and predictable behavior under stress.
Essentially, the pilot shows that Washington is prepared to bring digital assets into its market structure, but it will do so selectively, and in stages, with liquidity and risk management determining the pace
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