The CFTC's comment period on 24/7 futures trading has closed, and the open question is no longer whether markets can execute around the clock — it is whether clearing, funding, collateral and settlement can keep pace. Liz Kirby, Head of Market Structure at Tradeweb, laid out that gap in an interview with Traders Magazine, arguing that the infrastructure surrounding a trade still does not run on the same clock as an always-on market.

"It is one thing to execute a trade, but another to fund it, move collateral and settle it at the same time," Kirby said, pointing to weekends as the point where the mismatch becomes most acute. Clearing, margining, collateral management, custody and settlement remain highly interconnected processes that rely on traditional operating hours, fixed settlement windows and manual intervention.

What does true 24/7 trading change for liquidity?

Kirby frames continuous trading as a risk-management capability rather than a liquidity guarantee. True 24/7 trading gives investors the ability to react to information as events happen, rather than waiting for the next regional market to open. She cites U.S. Treasuries as evidence of existing demand, where liquidity already follows the sun across Asia, Europe and the U.S.

But she draws a hard line between an open market and a liquid one. "Keeping a market open does not automatically create liquidity," Kirby said. Activity is still likely to concentrate around regional trading hours and key events, so the challenge is ensuring that additional hours offer meaningful liquidity rather than spreading existing activity more thinly. As markets become more electronic and automated, better data and cross-market connectivity should help participants locate and access liquidity as conditions change.

Where are the infrastructure gaps?

The gaps sit across the post-trade stack:

• Clearing and margining still tied to traditional operating hours
• Funding dependent on the traditional banking day
• Collateral management requiring manual intervention
• Custody and settlement constrained by fixed settlement windows

Weekends expose the problem most clearly. An always-on trading market could remain constrained, Kirby argues, by an infrastructure layer that effectively closes overnight or on weekends.

What is already working?

Tradeweb has run concrete tests of weekend settlement mechanics through its work with industry participants on the Canton Network. The firm has demonstrated U.S. Treasury financing outside traditional settlement hours, including on weekends, using tokenized Treasuries and digital cash. More recently, Tradeweb facilitated a real-time transaction pairing a tokenized U.S. Treasury with tokenized cash, showing how the security and cash legs can move together without traditional settlement timing constraints.

That matters for desks because it separates what is demonstrated from what is asserted: tokenized collateral and digital cash have moved HQLA outside traditional market hours in live tests, not merely in white papers.

What does this mean for FCMs and institutional firms?

For FCMs and institutional firms, 24/7 trading means margin and collateral management would need to become 24/7 as well. If positions can move at any time, firms need the ability to respond to changing exposures, meet margin requirements and mobilize high-quality collateral outside the traditional banking and settlement day.

Kirby identifies three operational priorities:

• Automation of processes that currently depend on fixed windows or manual steps
• Real-time visibility into exposures
• More efficient collateral mobility across custodians, venues and settlement systems

Tokenization and programmable settlement, in her view, could ultimately automate processes that currently depend on fixed windows. Tradeweb's 24/7 U.S. Treasury financing work — where tokenized collateral and digital cash enabled financing outside traditional market hours — provides what she calls an early example of how high-quality liquid assets could be mobilized in an always-on environment.

What comes next?

The CFTC has closed its comment period; the rulemaking record is now built. The binding constraint on 24/7 futures, on Kirby's assessment, is not execution technology but the funding, collateral and settlement layer behind it. Whether regulators and market infrastructure operators extend that layer's operating hours — or replace fixed windows with tokenized, programmable alternatives — will determine when round-the-clock futures move from proposal to practice.