TD Cowen says the CFTC's proposed framework for leveraged and margined crypto trading may be too late as the 2028 election cycle approaches. Jaret Seiberg, managing director at TD Cowen's Washington Research Group, said the agency likely cannot finish rulemaking until early 2028. Seiberg said the timing raises the risk that the rule will never be finalized. Seiberg warned that accelerating rulemaking could increase the risk of a judge blocking the rule on procedural grounds. Seiberg expects legal challenges could extend beyond 2028 even if the agency proceeds carefully.