regulation · CFTC · Tokenized Collateral · Recordkeeping
CFTC Staff Expands Its Crypto and Blockchain FAQs
The updated guidance addresses tokenized forms of permitted customer-fund investments and the use of blockchain systems for regulatory recordkeeping.

What happened
Staff from the CFTC's Market Participants Division, Division of Market Oversight and Division of Clearing and Risk updated the agency's frequently asked questions on crypto assets and blockchain technologies.
The additions address two practical questions: how customer funds may be invested in tokenized forms of otherwise permitted investments, and how blockchain systems may be used to satisfy regulatory recordkeeping requirements.
The FAQs build on the CFTC's earlier Tokenized Collateral Guidance and a 2026 staff no-action position concerning digital assets accepted as margin collateral.
Blue Rogues read
This is incremental infrastructure guidance, but that is precisely why it matters. Tokenization becomes usable inside regulated markets when operational questions—custody, records, permitted investments and auditability—can be mapped to existing obligations.
The update suggests that a blockchain representation does not automatically disqualify an otherwise permitted asset or recordkeeping process. It also does not erase the underlying legal tests.
What this confirms
CFTC staff is providing a pathway for registrants and registered entities to evaluate tokenized permitted investments and blockchain-based records under existing regulatory requirements.
What it does not confirm
The FAQs do not declare every tokenized asset acceptable as customer-fund collateral. They are staff guidance, not a blanket Commission rule, and firms remain responsible for the underlying asset's eligibility and their compliance obligations.
Sources and disclosures
Primary source: CFTC release 9303-26 dated September 24, 2026, together with the agency's referenced staff guidance. Blue Rogues does not extend the FAQs beyond the activities and entities they address.
Update note
Observed September 24, 2026 during the 23:11–23:45 BRT editorial window. Review the updated FAQ text and any later Commission action before publication.
