per the CFTC's own notice, a fully paid crypto position that sits only on an exchange's internal book isn't "delivered" yet

#CFTCSeeksCommentOnRetailDigitalAssetFramework is trending like it's new. it's the October 5 advance notice, the one we went through on October 6. still no rule text

what is new:
🔸 Federal Register, October 13
🔸 comments due December 14

the delivery line is the one I keep rereading. until "actual delivery", that position stays under the Act

possession and control may require holding the private keys

if a platform offers margin or leverage at all, the "covered offer" can reach every retail trade there, fully paid ones included

to the regulator, a balance screen and a key in your hands are two different things. a US notice, the same old not-your-keys logic

#CFTC