The United States has made a clear distinction between crypto assets suitable for trading and assets best suited for use as collateral in the derivatives markets.
On December 8, the Commodity Futures Trading Commission (CFTC) authorized Futures Commission Merchants (FCMs) will accept Bitcoin, Ethereum and USDC as eligible margin under a digital asset pilot program.
This move brings these tokens into the operational framework used for clearing futures and swaps, placing them alongside more traditional forms of performance bonds, such as Treasuries 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 falls within US bankruptcy protections, segregation rules and ongoing monitoring, rather than in offshore environments.
According to her:
“This need has never been more important given recent customer losses on non-US crypto exchanges.”
The Safe Harbor Strategy
The pilot project aims to give institutional traders the ability to collateralize positions with assets cleared under US supervision, rather than relying on liquidation engines from offshore exchanges.
Under the new regime, BTC, ETH and USDC can be margined, 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 large-scale offshore trading platforms while preserving the CFTC’s long-standing safeguards for leveraged derivatives activities.
The program also creates a framework for assessing tokenized collateral in practice, giving regulators insight into how digital assets are performing within a system built for continuous margin calls and intraday risk controls.
Heath Tarbert, chairman of Circle, said:
“Deploying prudentially controlled payment stablecoins on CFTC-regulated markets protects customers, reduces settlement friction, supports 24/7 risk reduction, and advances US dollar leadership through global regulatory interoperability. Enabling near real-time margin settlement will also reduce the risk of settlement failures and liquidity shortages on evenings, weekends and holidays.
XRP, Solana and Cardano are missing
The pilot’s limited set of assets 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 ease of valuation during periods of stress.
For context, analysts noted that XRP’s regulatory profile has evolved significantly over the past year, but its suitability as collateral would require a higher threshold. This is because collateral frameworks favor assets that can be reliably valued and liquidated without disrupting markets.
XRP’s domestic liquidity, while significant, is significantly lower than that of BTC and ETH, which likely played a role in the program’s early asset selection.
Furthermore, RLUSD’s absence sparked a similar discussion.
Although Ripple’s payments stablecoin is gaining popularity and was recently included in Singapore’s MPI extended licenses for cross-border services, its domestic footprint remains small compared to USDC.
As a result, the CFTC may have chosen to start with the stablecoin that currently serves as the main regulated dollar proxy in the US on-chain markets.
Still, Ripple’s leadership has publicly embraced the pilot as a win 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 provides the regulatory clarity needed to move the industry forward. This move will unlock greater capital efficiency and solidify U.S. leadership in financial innovation. At Ripple, we look forward to continuing to work with the CFTC and the industry to ensure the safe and responsible scaling of digital assets.”
The tone of this response suggests that Ripple does not view the pilot 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 on which other stablecoins, such as RLUSD, could eventually ride once they meet required liquidity thresholds.
Meanwhile, the CFTC did not directly comment on the rationale for specific exclusions. However, the limited list is consistent with the pilot’s objective to assess tokenized collateral across a tightly controlled set of assets before considering a 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 outlines of a hierarchy of regulations: some assets can be traded under supervision, while even fewer can serve as collateral for margining.
For the sector, the pilot is both a milestone and a limitation. It brings digital assets closer to the core of America’s financial infrastructure while clarifying the standards needed to achieve that level of depth, stability, custodianship and predictable behavior under stress.
In essence, the pilot project shows that Washington is willing to incorporate digital assets into its market structure, but it will do so selectively and in phases, with liquidity and risk management setting the pace.