SIFMA Asks SEC and CFTC to Halt Equity Perpetuals Filings

SIFMA filed a comment letter on November 3, 2026 with the SEC and CFTC urging both agencies to block, at least temporarily, four designated contract markets' filings to list and trade perpetual futures on individual equity securities. The products, dubbed "Equity Perpetuals," would trade as security futures, and SIFMA argues the existing framework does not fit them.

The four rule filings come from designated contract markets (DCMs), exchanges registered with the CFTC. Each filing seeks approval to list perpetual futures on single equity securities — contracts with no expiration date, unlike traditional single stock futures. That structural difference sits at the core of SIFMA's objection. The security futures framework, the letter notes, was designed for expiring contracts, and Equity Perpetuals "differ meaningfully" from the products that regime was built around.

SIFMA asks the two Commissions to use statutory tools already available to them to force a broader, public review before any launch.

What does SIFMA want the agencies to do?

The letter lays out three specific requests:

• Assess market impact first. The Commissions should evaluate how Equity Perpetuals would affect the underlying equity markets, including liquidity, price discovery, capital formation, investor protection, and cross-market manipulation risk in what SIFMA describes as a nearly continuous trading environment.
• Resolve the classification question. The agencies should determine whether Equity Perpetuals belong in the security futures bucket at all, or whether they are more properly swaps or security-based swaps — a question the SEC and CFTC themselves raised in a joint request for comment earlier this year.
• Use their suspension powers. SIFMA points to the CFTC's authority to stay the DCM filings, and to the SEC's authority to abrogate them and require refiling under Section 19(b)(1) of the Securities Exchange Act, the provision that mandates public notice and comment.

The invocation of Section 19(b)(1) is the operative ask. That statute gives the SEC a path to disapprove a proposed rule change and compel a refiled version subject to the full comment process — converting what would otherwise be self-certifying DCM filings into a public rulemaking.

Kenneth E. Bentsen, Jr., SIFMA president and CEO, said: "Equity Perpetuals raise important questions about how these products would interact with the U.S. equity markets that investors and issuers rely on. We encourage the SEC and CFTC to work through those questions together, with the benefit of public comment, before these products are offered to investors."

What does this change for trading desks?

Nothing yet. The filings remain pending, and SIFMA's letter is advocacy, not a mandate. No listing date, compliance deadline, or effective date appears in the source material. What the letter does is raise the procedural cost of approval: if either Commission takes up the stay-or-abrogate route SIFMA proposes, the four DCMs face a delay measured in months of notice-and-comment rulemaking rather than a routine certification cycle.

The classification question carries the longer tail. If the agencies conclude Equity Perpetuals are swaps or security-based swaps rather than security futures, the products move into a different regulatory perimeter — one with different margin, clearing, reporting and trading requirements, and a different division of jurisdiction between the two Commissions. SIFMA's letter cites the joint request for comment the agencies issued earlier this year as evidence the question is already open.

The cross-market manipulation point is the one most directly relevant to execution and surveillance workflows. A nearly continuously traded derivative on a single equity, with a funding mechanism tied to the cash market, would require surveillance coordination between equity and futures venues that current single stock futures never demanded.

SIFMA has posted the full comment letter on its advocacy page. Both Commissions must now decide whether to let the DCM filings proceed on their normal timeline or invoke the stay and abrogation authorities SIFMA has put on the table.