The Commodity Futures Trading Commission’s 17-day experiment with letting U.S. exchanges convert perpetual-style index futures into true perpetual contracts ended quietly on October 20 — with no exchange publicly announcing it had used the relief, and with no extension from the regulator. The window’s closure turns the page on Staff Letter 26-29 and shifts attention to the permanent approval track — and, more consequentially, to a bigger decision due around November 2: whether Coinbase Derivatives gets to list perpetual futures on individual U.S. stocks.

What the relief did — and what it didn’t

Staff Letter 26-29, signed October 3 by D.J. Hennes, acting director of the CFTC’s Division of Market Oversight, and published October 5 as press release 9308-26, answered an October 1 request from Coinbase Derivatives filed under Commission Regulation 140.99. It confirmed that staff would not recommend enforcement action if a designated contract market removed the expiration dates from its existing perpetual-style broad-based security index futures and made the amendments effective immediately upon publication — skipping the normal 10-business-day waits under Regulations 40.6(a)(3) and 40.6(b)(1). Staff also said it would not seek a stay of those certifications under Regulation 40.6(c)(1).

The relief came with strings attached: exchanges had to solicit feedback from traders holding open positions, give at least five calendar days’ notice, offer a chance to exit under the old terms, provide risk disclosures, and change nothing else material. Staff warned that changing an expiration date could move prices in ways that “may be impossible to anticipate.” The amendments still had to be filed under Regulation 40.5 or 40.6 with a certification of compliance. The full text is available in the CFTC’s no-action letter.

Three things the letter did not do: it covered only broad-based security index futures — not single stocks, not crypto perpetuals; it represented the views of Division staff only, not the Commission; and it was explicitly temporary, with the no-action positions expiring October 20, 2026.

The window-utilization scorecard: 5 contracts, 0 conversions

The window’s most telling fact is what didn’t happen. Macrometer’s review of public records found no announcement from any designated contract market that it removed expiration dates under the relief during the October 3–20 window. Media coverage as recently as October 19 still referred to Coinbase’s US500 contract as a “Perp Style Futures” product.

Source and methodology note: the contract list is drawn from Coinbase’s request letter as reported in secondary sources (tradingkey/cryptocompass); the request letter reportedly named six contracts including Coin50, a crypto index that likely fell outside the relief’s broad-based-security-index scope. The conversion count reflects public records only — Regulation 40.6 filings are not always publicized, so this is a floor, not a certainty that nothing was filed.

Why so little use? A five-day notice requirement inside a 17-day window left little room; the certification work and price-risk disclosures were non-trivial; and exchanges may simply have decided to wait for the permanent route rather than rush a temporary one. Kalshi’s example — a full Reg 40.3 review completed in under two months — suggests the formal path may now be nearly as fast.

The bigger clock: Coinbase’s single-stock perps

The real decision the market is watching is Coinbase Derivatives’ September 18 filing for perpetual futures on individual U.S. stocks and ETFs — the filing that could bring 24/5 equity trading, already common offshore, to the regulated U.S. market. Key facts:

Methodology note: the ≈November 2 date is Macrometer’s calculation from the September 18 filing date and the published 45-day review window; the CFTC has announced no decision date, and the review can be extended. The CFTC product register still showed the contract as “Approval Pending” in the latest media checks this week.

The proposal covers a first set of roughly 50–60 stocks — including Apple, Microsoft, Tesla and Nvidia, per the Wall Street Journal — with cash settlement, no share ownership, trading Sunday 8 p.m. to Friday 5 p.m. ET, and a named central counterparty of Nodal Clear LLC rather than Coinbase’s own clearinghouse. Because the contracts are single-stock futures, they sit under joint CFTC–SEC jurisdiction, with compliance certified under Regulations 41.21–41.48.

The permanent track is already open

Staff Letter 26-29 is gone, but the route it gestured at was already working. The Commission’s June 3 policy statement (91 Fed. Reg. 33160) held that perpetual contracts on assets other than digital commodities must go through review and approval under Regulation 40.3. KalshiEX filed its US500 perpetual under that rule on August 18; the Commission deemed it approved on October 2, and Kalshi opened trading on October 6 — the first U.S. stock-index perpetual, tracking the MerQube US Large Cap Index with a $1 multiplier per index point. The staff letter itself cited Kalshi’s contract as the precedent.

This is the template future filings will follow — and they may not be Coinbase’s alone: Kraken’s parent company Payward is also pursuing perpetual products for U.S. customers, while CME took the dated route in July, launching 77 single-stock futures that require periodic rollovers.

Why the demand case is hard to ignore

The regulatory debate is happening against a backdrop of enormous offshore demand. CoinGecko’s “TradFi on Crypto Exchanges” report found perpetual futures on real-world assets grew from $0.23 billion in volume at the start of 2025 to $347.17 billion in May 2026 — a 1,472-fold increase — with $1.32 trillion in TradFi perpetual volume year-to-date in 2026 versus $104.21 billion in all of 2025. Tokenized-equity perpetuals alone hit $34 billion in monthly volume in May, still under 1% of traditional equity volume but climbing fast, with Binance, MEXC and Hyperliquid leading the category. (CoinGecko, TradFi on Crypto Exchanges Report 2026)

For U.S. equities specifically, KalshiEX’s own CFTC filing cited a comment letter reporting more than $480 billion in notional trading volume across Hyperliquid’s HIP-3 single-stock perpetual markets as of August — a regulated-U.S. alternative would be competing with a deep, entrenched offshore market from day one.

Bull and bear cases

The constructive case: a permanent, regulated U.S. path for perpetuals now exists and has been proven once; Coinbase arrives with a full-stack buildout — futures commission merchant, designated contract market, and, since September 28, a registered clearinghouse; and the $1.32 trillion year-to-date offshore market shows traders want the product. Competition between Kalshi, Coinbase and Payward should benefit liquidity and pricing.

The cautionary case: approval is not guaranteed, and the 45-day clock can be extended; the SEC leg adds a second regulator with its own timetable, and the September setback for the CLARITY Act left broader market-structure questions unresolved. Funding-rate mechanics and leverage make perps unforgiving, after-hours liquidity is unproven onshore, and offshore incumbents start with a large head start. Coinbase’s push fits a broader rewiring of global finance — a theme that ran through the IMF’s annual meetings in Bangkok.

What to watch next

Three dates and documents matter from here. First, the ≈November 2 estimate for the end of the CFTC’s 45-day review of Coinbase’s single-stock filing — watch the CFTC product register for any change from “Approval Pending.” Second, the SEC’s parallel decision on the Form 1-N and the joint security-futures framework. Third, whether Kalshi or Coinbase files the next product through the Reg 40.3 template, and how Kalshi’s US500 contract trades in its first full month. Meanwhile, Wall Street’s trading desks just came through a strong third quarter — suggesting the appetite for new derivatives products is hardly in doubt.

This article is for informational purposes only and does not constitute financial advice.