The U.S. Commodity Futures Trading Commission’s Market Participants Division has reissued Staff Letter 25-40, updating the definition of “payment stablecoin” under its no-action framework to expressly include stablecoins issued by national trust banks, the agency said.
The revised letter reaffirms the division’s existing no-action position allowing registered futures commission merchants to accept certain non-securities digital assets, including payment stablecoins, as customer margin collateral and to hold qualifying payment stablecoins in segregated customer accounts.
Payment stablecoin definition expanded
In the version of Staff Letter 25-40 originally issued on December 8, 2025, the Market Participants Division took a no-action stance on specific requirements applicable to futures commission merchants that accept certain non-securities digital assets as customer margin collateral, including payment stablecoins.
After issuing the letter, division staff became aware that payment stablecoins that otherwise met the definition in the letter could be issued by a national trust bank, an issuer type not explicitly referenced in the original text. The division said it did not intend to exclude national trust banks from eligibility and therefore reissued the guidance with the expanded definition.
No-action position unchanged
The updated Staff Letter 25-40 maintains the Market Participants Division’s no-action position on certain regulatory requirements for futures commission merchants that accept eligible digital assets as margin collateral, subject to the conditions outlined in the letter, including valuation and segregation standards.
The press release did not announce further modifications to the scope of the no-action framework beyond the definitional change.
