FIA responded to the US Commodity Futures Trading Commission's consultation on extension of standard futures contracts to 24/7 trading and on perpetual contracts referencing physically delivered or storable energy commodities.
FIA encouraged the agency to assess 24/7 and perpetual products through two different lenses:
- readiness and
- appropriateness.
Assessing readiness requires a whole-of-market analysis. FIA urged the Commission to consider whether and how potential changes to infrastructure are available to, and can be adapted for use by, all users of the relevant markets.
Appropriateness requires product-by-product inquiries regarding contract specifications, the collective needs of hedgers, the extent to which the market is a benchmark for other contracts and other cash-market relationships. FIA detailed both readiness and appropriateness considerations, with a particular focus on energy markets.
