
Ondo SEC CFTC comment letters propose new approaches to perpetual futures, portfolio margining, tokenized collateral and on-chain reporting.
Author: Kritika Gupta
2nd September 2026- Ondo Finance filed three joint SEC-CFTC comment letters on August 24, arguing that existing U.S. law already lets regulated single-stock perpetual futures come onshore. The company announced the filings on September 2.
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Ondo Finance Proposes Functional Regulatory Standards To SEC And CFTC @Ondo submits three formal comment letters to the SEC and CFTC, advocating for a modernized regulatory framework for perpetual futures, portfolio margining, and market data reporting. It notes that the https://t.co/xT7W8hWcR0
01:54 PM·Sep 2, 2026
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All three letters were signed by General Counsel Mark Janoff and filed with affiliate Oasis Pro Markets. Ondo says the filings “should be read together.” They cover one connected problem: how old rules treat new market machinery.
The three Ondo SEC comment letters respond to a joint SEC-CFTC harmonization effort launched in March. Each targets a separate request for comment, not a proposed rule.
The first letter covers product classification of perpetual futures. The second addresses portfolio margining. The third deals with market data reporting.
Together they push a single thesis. Ondo argues that current law was built for expiring futures, siloed margin accounts, and after-the-fact swap reports. Its live stack, it says, does those same jobs with different technology.
A traditional future expires on a set date. A perpetual never does, so its price tracks spot through a recurring funding payment between longs and shorts.
In the first letter, Janoff argues a cash-settled single-stock perpetual can already qualify as a security futures product. According to the filing, the statute simply does not require a fixed expiration date.
“Nothing in the statutory definition of a security futures product requires a fixed expiration date,” Janoff wrote. He asked both agencies not to write a new categorical rule and instead engage staff on product-specific filings.
How Ondo’s three SEC-CFTC comment letters compare
The second letter turns to how positions get margined. U.S. rules still often force securities and futures into separate accounts, which ties up capital.
Consider a trader who holds tokenized Nvidia stock and shorts an Nvidia perpetual. That book is mostly basis risk, yet the rules treat it as two full bets.
Janoff argues margin should follow the real economics of the position. He also asks regulators to recognize tokenized real-world assets, including tokenized equities, as eligible collateral. The stated goal is to support onshoring of perpetual derivatives on U.S.-listed securities.
The third letter tackles data reporting. Dodd-Frank built repository pipelines so regulators could reconstruct opaque over-the-counter markets after the fact.
On a public chain or an attested enclave, Ondo SEC CFTC says, the trade itself is already the report. Forcing a second copy into a repository just adds noise.
Janoff wants regulators to define reporting by outcomes, meaning what they can see, how fast, and how verifiably. Where a market already publishes a cryptographically verifiable record, he argues, that record should satisfy the obligation.
Ondo’s theory sits inside a live legal fight. On June 18, CME sued the CFTC, arguing perpetuals are swaps rather than futures.
That distinction matters for Ondo. If perpetuals are swaps, its “just use the security futures statute” approach is exactly the question being litigated.
The regulatory backdrop is shifting fast. In May, the CFTC cleared the first U.S. bitcoin perpetual on a registered exchange, while equity underlyings stayed in a case-by-case review bucket. Consumer-protection group Better Markets has filed on two of the same dockets, signaling that the loosening will face pushback.
Ondo does not hide its stake in the outcome. Through Ondo Global Panama, the company runs a live single-stock perpetual platform. It settles in stablecoins and stays closed to U.S. customers.
Ondo Perps launched in July as what the company calls the first permissionless venue accepting tokenized equity as collateral. Ondo also reports roughly $4 billion in tokenized assets and leading market share in tokenized equities. Independent tracker DefiLlama lists on-chain assets near $3.70 billion across 16 chains.
So the filings read partly as policy and partly as product-market fit. A skeptical frame writes itself, and Ondo answers it by leading with the Panama platform rather than burying it.
The market shrugged. ONDO traded near $0.34 on September 2, down about 1.6% on the day. Volume still rose to roughly $81.6 million.
Over the past week the token slipped from the mid-$0.37 range. The letters, in short, did not act as a price catalyst, partly because the token carries no protocol fee switch.
Under the announcement post, one holder captured the mood plainly: “Products are winning. Token still has no plan.” This article is not financial advice. Always do your own research before making any investment decision.
For now, the ball sits with agency staff. No SEC or CFTC official has responded to Ondo’s letters. The comment windows on all three dockets have already closed.
Several open questions remain. Regulators have not said whether single-stock perpetuals count as security futures, swaps, or something new. They also have not stated any timeline from comment to final rule.
The real decision may come from the CME case and the harmonization dockets, not from replies to a blog post. Readers can follow the SEC comment files and the coming staff guidance to see whether Ondo’s functional-equivalence argument gains traction.
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