On 5 October, the CFTC’s Division of Market Oversight announced conditional no-action relief for designated contract markets converting certain perpetual-style index futures. The announcement includes protections for holders of existing positions and a stated expiry for the staff position.
The relief concerns a defined conversion process
The release addresses existing perpetual-style broad-based security-index futures converted into true perpetual futures by removing expiration dates. Conditions include participant feedback, advance notice, an opportunity to exit, risk disclosure and no other material contract-term changes. CFTC — Index-futures conversion relief, release 9308-26
DCMs must file amendments under Regulations 40.5 or 40.6 and certify compliance with the conditions. The announcement states that the no-action positions expire on 20 October 2026. It is a conditional staff position, rather than a general statement that every perpetual product or provider is authorised. CFTC — Index-futures conversion relief, release 9308-26
Existing positions make the transition an operating event
WFN analysis: changing a contract’s lifecycle raises a different operational question from listing a new instrument. Brokers need to explain which positions are affected and preserve the instructions customers receive about the transition.
An opportunity to exit is useful only when the communication and order-handling process are understandable. A technology review should identify the contract definition used by each connected system rather than assuming that a familiar product label proves consistent treatment.
The announcement also creates a time boundary. A staff position with a stated expiry should not become a permanent assumption inside an operating manual. Its scope and any later extension need their own records. This article does not assert that every venue has already completed a conversion.
Verify the venue’s filing and notices
Review the actual no-action letter, applicable filings and participant communications for the venue and contract being discussed. Check whether a later official record changes the announced expiry or conditions.
Reconcile contract identifiers, affected positions and customer instructions before evaluating a particular transition. The documented fact is a conditional route announced by staff; implementation at a specific DCM requires evidence from that venue.