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The CFTC had issued its request for comment on April 21, 2025, seeking public input on the potential uses, benefits, and risks of extending trading and clearing to a 24/7 basis. This inquiry was prompted by evolving market structures, particularly in digital asset markets, and growing interest in continuous operations within traditional financial markets.
In their joint response, ISDA, SIFMA, and SIFMA AMG emphasized that the feasibility of 24/7 trading and clearing must be evaluated holistically. They highlighted the critical interdependencies between various market participants, including:
* Market Participants: Asset managers, executing brokers, swap dealers, and futures commission merchants (FCMs) would need to adapt their business and staffing models to operate around the clock.
* Trading Venues: Designated Contract Markets (DCMs) and Swap Execution Facilities (SEFs) would need to restructure staffing, trading protocols, and surveillance/compliance mechanisms for continuous coverage.
* Middleware and Software Providers: Essential third-party service providers facilitating matching, trade affirmations, credit checks, and reporting would need to be operational 24/7.
* Clearing Systems: Clearing organizations would require robust systems for continuous clearing, margining, and default management.
* Payments Systems: The underlying payment infrastructure would need to support continuous collateral flows.
* Margining Frameworks: Mechanisms for real-time margining and collateral access during non-traditional business hours would be crucial.
* Default Management: Robust procedures for managing defaults in a continuous operating environment would be necessary.
The associations also underscored the need to consider the full range of potential impacts, including liquidity, price transparency, operational and technological challenges, and the associated costs of expanding to 24/7 operations. They welcomed further engagement with the CFTC to examine these complex issues more closely, suggesting that a comprehensive discussion and consideration of all factors are critical before any widespread implementation of 24/7 trading and clearing.
The move towards 24/7 trading in financial markets, while offering potential benefits such as immediate response to geopolitical events and increased liquidity, also presents significant challenges. These include concerns about increased market volatility, wider bid-ask spreads during off-peak hours, enhanced cybersecurity threats, operational issues for firms, and the need for new regulatory frameworks and safeguards to ensure market stability and investor protection.

Video courtesy of CSOB

Video courtesy of CSOB