FCMs & Trading Firms

CFTC-Ready Compliance for Digital Asset Collateral

CFTC Letter 26-05 introduced specific requirements for FCMs accepting stablecoins and digital assets as customer margin collateral. Kontext provides the tamper-evident audit trail, automated reporting, and segregation tracking you need.

The Challenge

Why FCMs need purpose-built compliance infrastructure

CFTC Letter 26-05 creates new obligations that legacy systems were never designed to handle.

New CFTC reporting requirements for digital asset collateral

CFTC Letter 26-05 introduces specific reporting and record-keeping obligations for FCMs accepting stablecoins and digital assets as customer margin collateral. Meeting these requirements demands purpose-built infrastructure.

Daily mark-to-market with haircut validation

Digital asset collateral must be valued daily using DCO reference prices with mandatory haircuts -- 20% minimum for non-BTC/ETH assets. Manual tracking is error-prone and unscalable.

Weekly reporting to the Commission

FCMs must submit weekly digital asset reports to the CFTC detailing collateral holdings by asset type and account class. Generating these reports manually consumes significant back-office resources.

Segregation calculation complexity across 3 account classes

Tracking segregation requirements across futures (4d), cleared swaps (22), and 30.7 secured accounts requires daily calculations with full audit trails for regulatory examination.

Cybersecurity incident documentation requirements

CFTC regulations require FCMs to document and report cybersecurity incidents promptly. Having tamper-evident logs of all digital asset operations is essential for incident response.

How Kontext Helps

CFTC Letter 26-05 compliance infrastructure

Purpose-built tooling for the specific requirements FCMs face when accepting digital asset collateral.

Collateral Valuation Logging

Log every collateral valuation with asset type, quantity, market value, haircut percentage, and valuation method. Full audit trail with tamper-evident cryptographic digest chains.

Automated Haircut Validation

Enforce the 20% minimum haircut for non-BTC/ETH digital assets per CFTC Letter 26-05 requirements. Configurable haircut rules per asset class and DCO reference pricing.

Weekly CFTC Digital Asset Reports

Auto-generate weekly reports for the Commission detailing digital asset collateral holdings by asset type, account class, and valuation method. Export in required formats.

Daily Segregation Calculation Tracking

Track segregation requirements across futures, cleared swaps, and 30.7 secured accounts with daily calculations and full audit trails for regulatory examination.

Incident Reporting

Commission Reg 1.11-aligned cybersecurity incident documentation and alerting. Tamper-evident logs ensure incident records cannot be altered after the fact.

Tamper-Evident Audit Trail

Every collateral operation is recorded in a cryptographic digest chain. Provide regulators with verifiable proof that records have not been modified since creation.

Code Example

Collateral valuation and weekly reporting

Use the CFTCCompliance class to log collateral valuations with haircut validation and generate weekly CFTC digital asset reports automatically.

  • Automatic haircut validation per CFTC Letter 26-05
  • Weekly report generation by account class and date range
  • Every valuation linked in a tamper-evident digest chain
  • Segregation tracking across futures, cleared swaps, and 30.7
  • Export in CFTC-required formats
fcm-compliance.tstypescript
import { Kontext, CFTCCompliance } from 'kontext-sdk';

const kontext = Kontext.init({
  projectId: 'fcm-collateral',
  environment: 'production',
});
const cftc = new CFTCCompliance();

// Log a collateral valuation with haircut validation
const valuation = cftc.logCollateralValuation({
  accountClass: 'futures',        // 'futures' | 'cleared_swaps' | '30_7_secured'
  assetType: 'payment_stablecoin',
  assetSymbol: 'USDC',
  quantity: 1_000_000,
  marketValue: 1_000_000,
  haircutPercentage: 0.02,        // 2% for payment stablecoins
  valuationMethod: 'dco_reference',
  agentId: 'collateral-agent',
});

console.log('Valuation ID:', valuation.auditId);
console.log('Digest:', valuation.digest);

// Generate the weekly CFTC digital asset report
const report = cftc.generateWeeklyDigitalAssetReport(
  'futures',
  new Date('2026-02-03'),
  new Date('2026-02-09'),
);

console.log('Report entries:', report.entries.length);
console.log('Total collateral value:', report.totalValue);
console.log('Export format:', report.format); // 'cftc_weekly'
Enterprise

Enterprise pricing for FCMs

FCMs require custom pricing, dedicated support, and SLAs that match the regulatory stakes. Our Enterprise plan includes unlimited events, priority support, custom integrations, and a dedicated compliance engineering team.

Custom pricing tailored to your collateral volume
Dedicated compliance engineering support
SLA with guaranteed uptime and response times
Custom report formats and integration support

Ready to meet CFTC Letter 26-05 requirements?

Talk to our team about how Kontext can support your FCM's digital asset collateral compliance infrastructure.