Innovative Digitized Products and Processes
Mission Statement: The Subcommittee’s objectives are:
- Educate ourselves, policy makers and the public about current issues raised by innovative digitized products and processes such as cryptocurrencies, smart contracts and blockchain or other distributed ledger technologies;
- Identify and study emerging legal and regulatory issues and their implications for such products and processes;
- Study and understand how the Commodity Exchange Act framework and other statutory and regulatory frameworks may intersect, and identify areas of conflict or other issues that overlapping laws may create; and
- Make appropriate recommendations to address the material issues identified.
Part 190 Rules
Mission Statement/Project Status: The Part 190 Subcommittee was formed in February 2015 jointly by the Derivatives and Futures Law Committee and Business Bankruptcy Committee to undertake a careful review of the CFTC’s Part 190 commodity broker bankruptcy rules to identify potential areas where they could be improved. The subcommittee submitted draft revisions in the form of model Part 190 Rules to the CFTC in September 2017. The CFTC proposed comprehensive amendments to Part 190 in April 2020 and adopted new Part 190 rules in December 2020. The model rules were the foundation for the CFTC’s Part 190 rulemaking. The CFTC Chairman honored the Part 190 Subcommittee at the December 2020 open meeting with the “Chairman’s Award for Regulatory Excellence” recognizing its work and contributions to the Part 190 rulemaking effort.