Compute Derivatives at the CFTC

• The Commission "should allow the cash and derivatives markets to develop together under its existing principles-based framework."
• "Requiring a single definition of “compute” at the outset could unnecessarily inhibit useful innovation."

MFA "represents the global alternative asset management industry." It has "more than 180 fund manager members, including traditional hedge funds, private credit funds, and hybrid funds." It writes that "MFA supports the responsible introduction and development of compute derivatives." The letter names no compute index, administrator, venue or provider, and cites no other comment on this docket. Signed by Jennifer W. Han, Chief Legal Officer & Head of Regulatory Affairs, with copies to Chairman Selig and DJ Hennes, Acting Director of the Division of Market Oversight. The letter is dated October 27.

• "Compute derivatives can be listed under the existing Core Principles and the Appendix C Guidance. We see no need for a new rule."
• On event contracts: "Contract terms should also state the precision of the index used for settlement and what happens when the index equals the strike."

Belief Systems "is a benchmark administrator for prediction markets." It publishes indices, a volatility measure and market-quality grades derived from prediction-market prices. It states: "We do not publish a compute index and have no compute market data." Prediction-market venues, "including some that have commented on this Request, may be licensees or commercial partners." It does "not ask the Commission to approve, designate, or endorse any index, administrator, or venue, including us." The letter names no compute index, venue or provider. It cites its August 2026 comment to the SEC on Novel ETFs, the IOSCO benchmark principles and Part 40. It offers to brief staff, including the Innovation Task Force. Signed by James Stewart, Founder. The letter is dated October 26.

• Look for the terms of rental-settled contracts, and any risk disclosure, "to state that the contract references the price of compute hours and not the value of the hardware, and to identify residual-value risk as distinct from rental-rate risk."
• "Where a submission presents a rental-settled contract as a hedge of GPU collateral, fleet value or residual value, look for evidence of how the reference index has moved with hardware prices for the same GPU class, or a statement that no such evidence exists."

Stoa "operates an institutional request-for-quote marketplace on which GPU servers and racks are quoted and sold for physical delivery." Its interest "is commercial" and includes "developing hardware price data, valuation analytics and price benchmarks." It is "not registered with the Commission in any capacity." It does "not ask the Commission to adopt new rules, to delay the contracts now under review, or to prefer any index." It does "not object to perpetual contracts in principle" and takes "no position on retail access." It cites the NYMEX Silicon Data submission, the ICE and Ornn and ICE and NATIVX announcements, and other comments on this docket by document ID. Among them are Architect, Polymarket US, DRW, DNA Compute, Compute Capital, Bandi and Su, FIA, Hydra Host, Clarke Index and CoopHive. It compares Baltic freight futures and vessel valuations, LME warrants and aircraft appraisal. Signed by Berat Celik, Chief Executive Officer. The letter is dated October 22.

• The Commission should "state expressly that it welcomes physically settled compute futures, and the commercial physical markets that support them, alongside cash-settled contracts."
• Confirm "that access to compute capacity is an exempt commodity, that dedicated reserved capacity is a nonfinancial commodity."

Multicoin "is an SEC-registered investment adviser, founded in 2017." It writes "as an investor." It has "invested in decentralized compute networks and marketplaces for several years." It expects "to allocate capital to the venues, intermediaries, and infrastructure that serve this market." It takes "no position on any particular index or venue." It cites other comments on this docket by document ID. Among them are Architect, The Digital Chamber, OneChronos, Paradigm and Andromeda, Kalshi, Polymarket, a16z, DRW, Jump, PMEX, DNA Compute, Better Markets, Dragonfly and Shadab. It compares two published H100 rates: Hyperstack at $3.20 per GPU-hour on demand and AWS Capacity Blocks at $5.970 per accelerator-hour. It also cites CoreWeave financing releases, a partner's October 8 post "Compute Capital Markets," electricity locational pricing and the COMEX aluminum Midwest premium contract. Signed by Gregory E. Xethalis, General Counsel; Daniel Leonardo, Deputy General Counsel and Chief Compliance Officer; and Jay Stolkin, Deputy General Counsel. The letter is dated October 20.

• "Clearly define what is being traded. Not all computing power is interchangeable, so contracts should identify exactly what is being priced."
• For on-demand, interruptible and reserved capacity: "We recommend separate contract series for these arrangements rather than combining them in one price."

RBL "is a boutique business law firm with offices in Rancho Santa Fe and Burlingame, California." It comments "rather than on behalf of any particular client." It states: "We support the development of a regulated market that helps businesses manage changes in the cost of computing power." It does "not recommend changing the existing routes for listing a new futures contract." The letter names no index, venue or provider. It cites Core Principles 3, 4 and 5, Appendix C and the June 2026 policy statement on perpetual contracts.

• "Define the measurement and its use: specify the population, rights, units, timing and how the derivative uses the index."
• "Assess incentives and conflicts: include coalitions of independent firms, administrators, verifiers and combined exposure across physical and financial contracts."

"Arkhai builds programmable markets for agentic economies, starting with compute." The filer is CoopHive Inc., doing business as Arkhai. The submission "draws on research in distributed computing, game theory, and agentic systems." Its recommendations "are contract-specific, not a general position on listing compute derivatives." It offers "conceptual analysis, not a completed audit, executed simulations or evidence that a particular index is fit for use." Its attack mechanisms "are hypothetical, not allegations." The letter names no index, venue or provider. It cites Duffie and Dworczak, “Robust Benchmark Design” (2021), and a FERC surveillance overview. Its assurance table cites FIPS 186-5, RFC 9162, RFC 9334 and NIST PEC.

• On Questions 3(c) and 3(d): "Cash settled compute futures based on an index should disclose, in addition to index data sources, calculation methodology, and price history, the index’s limitations and reasons it may not fully proxy and converge to compute’s underlying economic cost."
• Among the attributes of a well-constructed index: "Inclusion of a wide set of anonymized private, nonpublic transaction data."

The filer has "spent my career in Silicon Valley as a consumer of computing infrastructure, including running one of the first “compute trading desks” at Heroku nearly a decade ago." The letter adds "deep experience in the ensuing years at large infrastructure providers including Microsoft and Meta." No organization or title is given. It states that "the top three providers collectively account for approximately 63% of global cloud infrastructure revenue." It includes a chart of "three “H100” GPU indices, names redacted," normalized on August 4, 2025. It cites the AI Action Plan and Executive Order 14179.

• On Question 1(c), "the question should turn on whether the data can be made verifiable." It adds: "Non-public data is therefore not disqualifying under existing guidance. Unverifiable data should be."
• State that "cryptographic attestations and proofs may form part of a DCM’s record: under Core Principle 3, as evidence supporting index-input eligibility, methodology execution, and delivery terms."

Submitted "in my individual capacity." Shadab taught law at New York Law School for 14 years and is now "a Fellow at Stanford CodeX." He is "a co-founder of ICME Labs (icme.io), a company that builds cryptographic verification tools for AI agents." He states: "I therefore have a commercial interest in verification technology being usable in regulated markets." "The letter recommends no vendor, product, or specific technology." It names NYMEX Submission No. 26-370 and the Silicon Data methodology pages. In them it found "no description of attestation or audit of contributor inputs." It cites comments by FastGPU, Hyperbolic, Silicon Data, Voltry, TCX, InfraSight and others. Precedents include Chicago Board of Trade grain grading, the 2023 London Metal Exchange nickel warrants, IOSCO, LIBOR, ISDAFIX and Regulation Automated Trading. It also cites CME futures on the Nasdaq Veles California Water Index. The same letter is also posted as CFTC-2026-1850-0103, with a different comment-box summary.

• "I respectfully ask the Commission to make “recalculable, auditable, with published fallback settlement rules” an explicit listing precondition for compute futures contracts."
• "Methodology and raw panel data must be public and independently recalculable." That means "the panel composition, segment weights, and the calculation code or specification sufficient for a third party to reproduce the index from public sources."

Signed as an "Independent researcher." The research "focuses on the economics of compute and energy markets, including independent measurement of GPU rental-price index data sources." The letter states no affiliation. It says Silicon Data "states that its H100/B200 rental indices cover 80%+ of the GPU rental market." It names "DRW / Compute Exchange / Silicon Data" as one corporate group. It names Vast.ai, RunPod, gpuhunt and Scaleway public APIs as public sources. It cites Core Principle 3 and Appendix C to Part 38.

• "We recommend the Commission treat settlement by transfer of a claim ticket as the presumptively appropriate settlement form for compute futures, with cash settlement permitted only where the Appendix C index standard is met."
• In guidance, "expressly recognize settlement by transfer of a standardized verifiable claim ticket as physical delivery by document of title and as an alternative to cash settlement, with issuer capacity certification and registry-based deliverable-supply data."

The letter does not describe Abaxx's business. It states that "this comment does not ask the Commission to endorse a particular design through the RFC." On perpetual hedges, "The Company takes no position on which hedge structure is appropriate." It copies Abaxx CEO Josh Crumb, Chairman Selig, two advisers to the Chairman and the CFTC Innovation Task Force. The letter cites the W3C Verifiable Credentials Data Model 2.0, ISO/IEC 18013-5, UCC Article 7 and Merrill Lynch v. Curran. It names the CME Group and Silicon Data plan for H100 and B200 rental-index futures on NYMEX. It relies on the Michael Ravnitzky comment (0002) and the parallel RFC on perpetual energy contracts (RIN 3038-AF75).

• "We encourage the Commission to support multiple benchmark methodologies, provided each demonstrates verifiable resilience against manipulation and adheres to the IOSCO Principles for Financial Benchmarks."
• "Administrators should give priority to executed, arm’s-length transactions from secondary markets and brokerages." Where posted rates or bids and offers are used as inputs, "their weight should be limited and their sources identified."

"a16z is a venture capital firm that invests in seed, venture, and growth-stage technology companies." It reports "more than $100 billion of regulatory assets under management across multiple funds." Its new "Machine Age Fund" will invest in "all of the computer infrastructure on which AI runs, including chips, memory, networking, and storage." It discloses: "a16z crypto is an investor in Ornn." The letter names the Ornn Compute Price Index (OCPI), administered by Ornn Data LLC, and the plan by Intercontinental Exchange and Ornn, announced in May 2026, to launch GPU compute futures on the OCPI. It cites Platts, Argus and OPIS, power futures, the IOSCO benchmark and oil price reporting agency principles, and the White House AI Action Plan.

• "The Commission should distinguish three layers: GPU-hour products, compute indexes, and inference tokens."
• "I recommend beginning with a narrow open-weight grade, where the checkpoint can be identified and the serving configuration can be specified."

Kottos AI "develops inference routing and provider-performance measurement infrastructure." Its "gateway records request usage, timing, outcomes and cost estimates." The founder writes: "I have a commercial interest in this area, Kottos AI does not operate an exchange, and these views are my own." He "spent nine years in high-frequency and electronic trading at Virtu and UBS." The letter names Silicon Data's LLM Token Expenditure Index and Ornn's token indexes. It cites Moonshot AI's K2 Vendor Verifier results for Moonshot, Fireworks, Together and Chutes. It reports its own October 5 latency test of Claude Opus 5.5 on Anthropic's API and AWS Bedrock. It cites FINRA TRACE and comments by Michael Ravnitzky (0002), Silicon Data (0064) and Hydra Host (0069).

• FIA "believes strongly that only contracts that can be effectively risk-managed should be listed and cleared."
• "FIA encourages the Commission to articulate a public standard regarding spot and forward market data and when such data is sufficient to support compliance with Core Principle 3."

FIA is "the leading trade organization for the futures, options, and cleared derivatives markets globally." Its membership "includes clearing firms, exchanges, clearinghouses, principal traders, asset managers, execution firms, commodity firms, end users," and service firms. The letter names no compute index, venue or provider. It cites the IOSCO Principles for Oil Price Reporting Agencies (2012) and Principles for Financial Benchmarks (2013). It cites CFTC enforcement cases on Argus and Platts indexes, FX benchmarks and LIBOR. It names natural gas (LNG), freight and electricity as index-priced markets. Copies went to Chairman Selig, General Counsel Tyler S. Badgley and Aaron Levine.

• "Permit DCMs to develop commercially useful contract units, including GPU-hours with hardware and service characteristics necessary for economic comparability, without prescribing a single Commission-wide compute specification."
• "Treat inference throughput as a separate potential contract class where model choice, version, and measurement protocol can be standardized reliably."

"Dragonfly is a global investment firm that invests in cryptocurrency assets, infrastructure, applications, and markets." It "manages approximately $4 billion in assets across multiple funds." Its investments include "blockchain infrastructure, compute markets, and market data." It submits "on its own behalf and not on behalf of any portfolio company." The letter names Akash Network as a marketplace with on-chain orders, provider bids, leases and escrow payments. It cites 17 C.F.R. §§ 38.253 and 38.254. It also cites the Commission's June 2026 policy statement on perpetual contracts and the bitcoin perpetual futures contract permitted in May 2026.

• "Name the settlement series in the contract terms." For each print: "the effective contributor count, meaning the inverse of the sum of squared contributor weights; the share of inputs that are verified arm's-length executed transactions rather than posted or listed rates."
• "no restatement of history for contract months with open interest, other than correction of a calculation error or a falsified input within a published correction window with the original value kept."

"We write as a prospective intermediary." Its futures business, DNA Futures, "is being organized to introduce customer business in exchange-listed compute derivatives through a registered introducing broker." DNA Compute "owns graphics processing units and is developing additional capacity." It would participate "most likely as a seller of price risk." It has "no commercial relationship with any index administrator or exchange referred to in this letter." The letter names NYMEX Submission No. 26-370 (Silicon Data H100 and B200) and the ICE Futures U.S. OCPI H100 and B200 futures (Ornn). It names ICE with NATIVX, Nodal Exchange with Compute Desk, and Architect’s American Innovation Exchange. It also names Polymarket US, Bitget and a ProShares fund filing. It compares Silicon Data and Ornn readings on October 19, 2026. It cites SOFR futures, the ISDA IBOR fallbacks, FERC’s 2003 price index policy statement and the 2018 virtual currency staff advisory. It also cites power, freight and housing futures.

• "The Commission should not adopt compute-specific numerical thresholds or require that the compute cash market resemble mature commodity markets before contracts may be listed."
• Asks the Commission to "confirm that the “publicly available” element of the Appendix C Guidance is satisfied where the DCM publishes the final settlement price and the index methodology is public, even if constituent data are licensed or held in confidence."

Gemini writes from "the perspective of a registered designated contract market (“DCM”) that would be responsible for applying the Commission’s framework in practice." Its affiliates are Gemini Titan, a registered DCM, and Gemini Olympus, a registered DCO. Gemini Galactic Markets is a broker-dealer that has applied to register as an FCM. Gemini "is actively evaluating the listing of compute-referencing contracts." It "does not participate in compute cash markets and does not expect to administer its own compute reference price." It names no index provider. It cites Kalshi compute forward curves and compute futures announced by CME Group and Intercontinental Exchange. It also cites the IOSCO Benchmark Principles, the May 29, 2026 perpetual contracts policy statement and the AI Action Plan.

• Asks the Commission "to apply heightened review, rather than self-certification, to any settlement methodology designed or controlled by a firm with significant market-making, proprietary trading or capacity-ownership interests in the contracts or the GPU compute it prices."
• "Compute Desk cautions against any index whose input data comes from an on-demand compute marketplace, even if the data represents executed transactions."

"Compute Desk provides compute data and benchmark indexes for the GPU (Graphics Processing Unit) compute ecosystem." It "will serve as the index provider for" Architect’s American Innovation Exchange, a registered DCM. The letter describes its own indexes. They "use completed transactions executed by data partners, with counterparties anonymized at source, blended with published neocloud list prices." They focus on "bulk reserved “bare metal” GPU compute." General Index Limited calculates them under the IOSCO Principles for Financial Benchmarks. It states that "No proprietary transaction or listed data is included in the calculation of Compute Desk’s indexes." It also states that it "is not owned by, nor holds any investment by a market-making firm trading or intending to make markets in compute derivatives." The letter names Architect’s ComputeConnect EFP network, Nodal Exchange, NYMEX, ICE, CME and Bloomberg. It cites the FERC staff report on Western markets, the FERC price index policy statement and LIBOR.

• On Question 3(c): "I suggest the contract terms state what the settlement reference measures, and that basis of this kind is retained by the hedger." Its model text: "The position holder retains the exposure to whether contracted compute is delivered."
• On Question 2(g): "the enumerated standardization dimensions of that series and its change-control procedure should be described in the contract rules at a level a hedger can read and restate." It adds: "The proprietary normalization model stays proprietary."

Filed by Yifei Yang, "founder of PSYCHE and author of SQCD-1." It is "submitted in my own name and in the name of PSYCHE." It discloses: "I wrote SQCD-1, and PSYCHE, which publishes it, may offer services built on it." It "asks the Commission to adopt, designate, endorse or require no text, SQCD-1 included." Exhibit 1 quotes the settlement rules of eight electricity markets, including CAISO, ERCOT, MISO, NYISO, PJM and ISO New England. Exhibit 2 reads ten compute agreements filed with the SEC, including those of CoreWeave, Nebius, Applied Digital, HPE and Sharon AI. Exhibit 3 traces one credit-dispute clause across four of them. The letter names the Silicon Data, Ornn OCPI and Compute Desk series, NYMEX, ICE Futures U.S., Nodal Exchange, and Architect's ComputeConnect. It cites CME Degree Days Index futures as a precedent.

• "The Commission should apply these well-established and effective tools, support dated, perpetual, and event contracts, and preserve access for retail participants and commercial hedgers."
• "The Commission need not define one ubiquitous standard compute unit or product before permitting this important market to develop in the United States."

Kalshi files with its subsidiaries KalshiEX LLC, a designated contract market, and Kalshi Klear LLC, a registered derivatives clearing organization. It calls itself "the leading prediction market in the United States." It was "the first U.S. regulated exchange to offer perpetual contracts on digital commodities." It offers "compute forward curves" for B200, H200 and A100 rental prices. The letter names no compute price index. It cites Bitget's H100 and B200 perpetuals, the Freightos Baltic Index, NYMEX FBX01 futures, ICE Mid-Columbia power futures and CME WTI and Brent futures. It also cites the IOSCO principles, the EU Benchmark Regulation and LIBOR.

• On Question 2(c): an index "could initially consider transactions involving at least two eight-GPU nodes (16 GPUs) and up to and including 128 such nodes (1,024 GPUs), subject to appropriate requirements for cluster contiguity."
• "An index should clearly delineate how payment schedules are compared and what payment terms are assumed." It "should use the actual price after credits, rebates, and other applicable economic concessions."

Squaretower is a San Francisco startup that "works closely with some of the largest buyers and sellers of compute." It "operates an asset-light execution desk that manages compute portfolios for its clients." In August 2025 its team "developed an H100 price index using vetted U.S.-based compute suppliers." It supported the launch of a compute perpetual futures product, and a footnote states: "This market no longer trades." The letter cites Platts, Argus, Fastmarkets, SemiAnalysis, Gain AM and FERC's 2003 Policy Statement on price indices.

• "The illustrative contract is a forward on one GB300 NVL72 rack." The price is "Fixed USD per GPU-hour for the whole-rack unit, quoted in $0.001 increments." "No fixed 730-hour multiplier applies; months carry 672, 696, 720 or 744 hours."
• "The baseline is advance funding with an independent funds agent and evidence-based release to the service-charge creditor. Purchase funds are not available for construction before that trigger."

Appendix C to his October 19 comment (CFTC-2026-1850-0057), filed in a personal capacity. It sets out "a bilateral, physically performed forward purchase of a defined unit of compute for a fixed future service period." He states that it is "a design and an evidence method, not an executed agreement, a futures or swap specification, or an application to list anything." It also states that "nothing here concludes that any statutory forward exclusion applies." It "claims no compliance with or approval under" Appendix C to 17 CFR part 38. It cites IREN's Microsoft GB300 agreement at Childress, NYMEX Submission 26-370 and CFTC staff guidance on facility-use agreements.

• The reference framework "can establish separate indices or adjustments for hyperscalers and neoclouds."
• "Independent auditors and regulators must possess the structural capability to reproduce the results completely through either substantive reperformance of cleared transaction data or macro reasonableness testing utilizing analytical procedures."

Signed by Isabelle Stark of Stark Executive Advisory, New York. The letter does not describe the firm or state any interest. It names no index, venue or provider. It cites the move from LIBOR to SOFR, Brent crude quality differentials and locational marginal pricing in wholesale power. It states that multinode training performance on poorly tuned RoCEv2 "can drop by 30% or more due to packet loss."

• States that "no compute-specific rule is needed" and that "a new underlying commodity should not, by itself, turn the ordinary self-certification process into a requirement for Commission approval."
• The Commission should treat compute derivatives as including "binary and other fully collateralized contracts that settle to a compute price index, not only linear futures."

Polymarket US is a DCM. Its affiliate Adventure One QSS Inc. operates Polymarket International, which "is not available for trading within the United States." Since February 3, 2026, Polymarket International "has listed cash-settled binary contracts" on daily GPU rental price indices. They "have settled against two index families: those of Silicon Data, which CME Group has since selected for its compute futures, and Ornn." The letter describes Silicon Data, the Ornn Compute Price Index and the Compute Desk indices (with General Index). It names NYMEX, ICE Futures U.S., Architect Financial Technologies and the American Innovation Exchange. Its financing case cites CoreWeave and Nebius facilities and Clifford Chance. It cites Bandi and Su, Argus, the Baltic Exchange and the Kalshi BTCPERP approval. It offers to share settlement data with staff.

• "The existing Core Principles framework and the existing Commission regulations already provide the necessary regulatory oversight, anti-manipulation protection, and standards across all DCM product listings to support compute derivatives."
• For index-settled products, "the index methodology should be provided showing how it is reflective of the underlying cash market, is not readily susceptible to manipulation, and based on prices that are acceptable, reliable, timely, and publicly available."

Nodal Exchange is a DCM "at the forefront of innovation in the electric power, natural gas, and environmental futures markets." It states that it "plans to launch a new suite of GPU compute futures contracts on Nodal Exchange." The footnote to that sentence links to a Nodal Exchange release on launching compute futures with Compute Desk. Its clearinghouse is its wholly owned subsidiary Nodal Clear, a "Subpart C" DCO. "Nodal Exchange is part of EEX Group owned by the European Energy Exchange AG." The letter cites the 2013 IOSCO Principles for Financial Benchmarks and Appendix C to Part 38.

• "The Commission must ensure that compute derivatives contracts are able to be standardized, and are not susceptible to manipulation, before allowing them to trade on a DCM."
• On the question of parties best positioned to influence the reference price: "The answer is yes." It adds: "The CFTC needs to address this concern before commencing trading."

"Better Markets is a non-profit, non-partisan, and independent organization founded in the wake of the 2008 financial crisis to promote the public interest in the financial markets." The letter quotes Dave Friedman's Substack posts, including that Microsoft, Google, Amazon, "and to a lesser extent Oracle and Meta, control the vast majority of deployable capacity." It also cites Peter C. Earle (American Institute for Economic Research), a Cahill client alert and an Investment Executive article. It refers to its own August 26, 2026 letter on 24/7 trading and perpetual contracts.

• "Contracts can reference specific configurations, with contracts on new configurations introduced as they become available."
• "A clearly specified reference, or “par”, service may define the underlying, with transparent price adjustments for deviations from the “par” characteristics."

Joint comment by two Johns Hopkins University authors. "The Commission cites an earlier version of our paper, (Early) AI Compute Asset Pricing (Bandi and Su, 2026), in its request." The letter provides a revised version. It states: "We emphasize that our objective is not advocacy. Our contribution and interests are technical." Its model uses the 730 GPU-hour unit and business-day averaging in NYMEX Submission 26-370. It states that if futures prices "are mistakenly treated as a general guide to AI infrastructure investment and financing, they could distort credit decisions and amplify the credit cycle." It cites Becker (1968), Duffie and Dworczak (2021), Kumar and Seppi (1992), Zhang (2022), Morris and Shin (2002) and Kiyotaki and Moore (1997).

• "CME believes it is an appropriate, if not necessary, time for compute derivatives contracts to be offered to the industry for risk management and price discovery purposes."
• Its Compute Futures are "financially-settled futures based on the arithmetic average of the settlement prices for the Silicon Data H100 Rental Index (“SD-H100”) and B200 (“SD-B200”) Rental Index."

CME Group "owns and operates multiple futures exchanges registered as designated contract markets," including NYMEX. Trading in its Compute Futures "will be subject to the Rules of NYMEX." It states the indexes are "published by Silicon Derivatives Inc. (“Silicon Data”)." It states they have been "published continuously without interruption since inception," with a 729-day H100 history and a 395-day B200 history. It names AWS, Microsoft Azure and Google Cloud as hyperscale providers. It cites the findings section of the CEA, the July 2025 AI Action Plan and the Bandi estimate cited in the RFC.

• Supports guidance under which "the Commission could require that DCMs disclose the extent to which indices: (1) have a published methodology, (2) differentiate between transactions based on specifications and tenor, (3) are grounded in transaction-based inputs or, where quotes are used, are labeled as such, (4) publish the number of contributors and level of contributor concentration, and (5) are administered by an independent body."
• "We therefore urge the Commission to permit DCMs and others to develop and launch compute derivatives under appropriate oversight but without the delays or onerous conditions that would hamstring these critical markets."

"Paradigm is a frontier technology investment firm that invests and builds in crypto, AI, robotics, and across new frontiers from the earliest stages." "Andromeda is a GPU compute infrastructure company that sources, operates, and delivers dedicated compute capacity to AI developers." Andromeda reports demand "from compute providers seeking to lock in forward revenue," from investors and from lenders. The letter names no index or administrator. It cites CME Eurodollar futures volume in 1981 and the EEI Master Agreement. It cites CFTC Staff Advisory 18-14 and its 2025 withdrawal. It also cites the 2024 voluntary carbon credit guidance and its 2025 withdrawal. It refers to Paradigm's comment on perpetual contracts under RIN 3038-AF75.

• On Question 1(c): "PMEX does not believe a listed contract should settle to a reference price whose material inputs cannot be made available, on an appropriate confidential basis, to the listing DCM and the Commission for verification and surveillance."
• "Inputs should be executed transactions wherever available, with any indicative or assessed component separately disclosed as a percentage of the index."

PMEX "has applied for designation as a contract market." Its affiliate PMEX Clearing, Inc. "has applied for registration as a derivatives clearing organization." PMEX "intends to operate under the name Liquid Compute" and is building a physical compute venue. It states that "the parent company of PMEX publishes indices and does not take positions in contracts that reference them." It offers to "provide transaction-level data from our physical venue as it develops." The letter names no index or administrator. It cites the LedgerX DCO registration (2017) and DCM designation (2019), FERC Order Nos. 888 and 2000, and IOSCO Principle 3. It also cites Baltic Exchange freight indices and the 1999 to 2002 bandwidth trading attempts.

• "I suggest that contract specifications distinguish configuration and service terms from measured performance."
• "Any performance grade should state the software, workload, output-quality requirements and latency limits used to measure it."

Filed by the founder of OrchestraOS, "an early-stage project based in Germany that is working toward an operating system for AI inference and training." "No company has yet been formed." He holds "no positions in compute derivatives" and does "not currently offer an index or benchmarking service." He recommends "no particular benchmark or administrator." The letter cites a Silicon Data study of more than 3,500 GPUs at 11 cloud providers, the Silicon Data index methodology overview and Ornn's OCPI methodology. It also cites NVIDIA MLPerf results and the MLCommons inference rules. It builds on comments 0011 (ACU Markets), 0020 (Vandermolen Power), 0021 (Hivemind Capital), 0022 (Carvalho Ribas), 0030 and 0031.

• "ICE believes that the Commission should analyze proposed compute futures contracts under the existing principles-based regulatory framework for new products set forth in Core Principle 3 and the related guidance in Appendix C to Part 38."
• "We caution the Commission against issuing any “compute-specific” listing guidance as an outgrowth of this RFC. Such guidance would be unnecessary, could hinder innovation, and may have a negative effect on this developing market."

ICE operates "13 regulated exchanges and seven clearing houses," including ICE Futures U.S., a designated contract market. "ICE intends to list a suite of exchange-traded compute futures contracts." The letter does not name an index or administrator for those contracts. It cites the withdrawn voluntary carbon credit guidance and CFTC Staff Advisory No. 18-14 on virtual currency products. It offers power and freight as non-storable precedents. It cites the Bandi and Su estimate of $430 billion to $1.3 trillion a year in compute service flow. The letter is copied to Chairman Selig.

• "The Commission should clarify how designated contract markets (“DCMs”) should exercise reasonable, documented diligence on source authorization, methodology and reliability."
• On lawful sourcing: "Written administrator representations should identify the sources and confirm that the data is licensed or otherwise lawfully obtained and used, including any required source authorizations." It adds: "Licensing the finished index does not establish rights to its underlying inputs."

"Vast is an AI compute platform." In the 30 days ended October 14, 2026, "more than 2,500 providers earned revenue from more than 34,000 distinct customer accounts across more than 650,000 executed GPU rentals." It "offers data generated by its platform for licensing and discloses its commercial interest in that activity." Its Terms of Use "restrict systematic or automated extraction and the use of its data in indexes or benchmarks without a separate written agreement." Its logs show "sustained automated retrieval of listing and pricing data by third-party accounts." That collection continued after a July 24, 2026 licensing notice and a September 1 terms update. Vast "makes no allegation that a particular published index uses that data." The letter names no index, venue or administrator. It cites Appendix C to Part 38 and Rule 38.253.

• "The Commission should confirm that compute derivatives can list on regulated U.S. DCMs when the contract is well specified and the settlement reference is robust." It "should not presume that cash settlement is the only viable design."
• "The Commission should instead articulate the standards that any compute settlement reference should satisfy." These cover methodology, data sufficiency, governance and independence, manipulation controls and regulatory access.

PTG "is an association of firms that trade their own capital on exchanges in futures, options, and equities markets worldwide." Its members "would quote, arbitrage, and provide depth" in these contracts. It states "a direct interest in whether, and on what terms, these products trade." It "does not recommend that the Commission endorse any particular index, benchmark administrator, venue, provider, hardware class, or contract structure."

• "State that CEA section 9(a)(2) applies to reports made to compute price index developers, whether or not a compute contract is listed."
• Each settlement input should come from "a registered entity that has accepted a code of conduct" or be "a public, executable posted offer observed directly by the index administrator and independently verified for fillability." A verified transaction "always carries more weight than an offer."

A follow-up to its September 15 letter (CFTC-2026-1850-0011). The same letter is also posted as CFTC-2026-1850-0061 and CFTC-2026-1850-0062. It proposes pricing compute on "a unit of delivered work, defined by an independent, audited and published measurement standard." It cites natural gas pricing in MMBtu as the precedent. It names the MLPerf results published by MLCommons as existing measurement. It states that "ACU Markets has no relationship with MLCommons." Its data proposals follow the FERC 2003 price index standards. It sets out four stages. A contract on a single specified grade "can list at Stage 2." It states a commercial interest and that it "has built an index methodology to these criteria."

• "The Commission should encourage compute quality grades calculated uniformly across providers, so that an index compares like with like and quality is priced transparently."
• An index should "publish a separate series for each grade," and a series should "serve as a settlement reference only once it meets minimum depth and contributor thresholds."

Hydra Host "deploys, leases, and manages SI compute infrastructure for the leading super intelligence platforms." It is "an NVIDIA Cloud Partner specializing in distributed, bare-metal compute infrastructure." It states that "Hydra’s transactions never settle in cash." It describes itself as "among the largest contributors" of completed-transaction prices to "a leading independent compute price index expected to serve as a settlement reference." The letter does not name that index. It suggests the Commission could invite the National Institute of Standards and Technology to help define grades.

• "No new regulations specific to compute derivatives are needed; rather, the Commission should hold DCMs to design and surveil compute contracts with the same rigor and uniformity across venues that it expects for established commodities."
• "Compute derivatives can be listed today, provided contract design begins where the asset is well defined." It names two paths: "physically settled futures defined around a narrow view of the asset, and cash-settled contracts on indices that are only as broad as the observable data supports."

A follow-up to its September 24 meeting with CFTC staff (CFTC-2026-1850-0024). OneChronos "develops and operates combinatorial auctions and mathematical optimization mechanisms for capital and commodity markets." It has applications pending to register "OneChronos DCM LLC as a designated contract market" and OneChronos SEF LLC as a swap execution facility. It cites OneChronos Labs, chaired by Professor Paul Milgrom. It reports about $6.3 million of Kalshi GPU rental contract volume through October 11, 2026. It charts four anonymized H100 rental indices.

• Recommends "that each DCM submission under 17 CFR 40.2 or 40.3 for a compute derivative include an Input Evidence Profile for the settlement reference price." The profile shows input classes, contributor depth, adjustments, exclusions and assurance.
• On Question 1(c): "Inputs the DCM is unable to produce on request carry zero weight in the settlement value."

Solutions by Jewel is "a global AI governance advisory firm serving mid-market and enterprise organizations." It cites its own AI Decision Record v2.0 and AI Governance Architecture V2.0 as the basis for its proposals. It names the Silicon Data H100 Rental Price Index, the Ornn Compute Price Index (OCPI) and the CME Group H100 and B200 rental index futures. It cites perpetual GPU and DRAM futures on Architect Financial Technologies’ AX exchange. It offers CFTC Staff Advisory No. 18-14 as a model.

• "The Commission should therefore permit exchanges to develop both structures," fixed-date and perpetual, "where the contracts satisfy applicable requirements under the Commodity Exchange Act and Commission regulations."
• "The Commission should focus on the integrity of the reference benchmark and the mechanism connecting the perpetual contract to it."

CCI describes itself as "a global alliance of leaders within the digital assets industry." Its Digital Energy Council "brings together leading companies operating across the energy, digital infrastructure, artificial intelligence (AI), and digital asset industries." The letter sets compute beside the histories of WTI crude, Henry Hub natural gas, electricity and Bitcoin futures. It cites a Hyperliquid Policy Center paper on perpetual futures.

• "We encourage the Commission not to delay listing until the physical market standardizes, nor to treat all compute derivative proposals as a single monolithic category."
• A listing DCM "should verify that the settlement index administrator adheres to the IOSCO Principles for Financial Benchmarks." Here "mere self-certification by an administrator is insufficient."

Silicon Data describes itself as "an independent benchmark administrator and market intelligence platform for the AI compute economy." It "does not trade compute derivatives and does not own, lease, or hold GPU capacity." Its shareholders "include financial institutions and trading firms." Its CEO, Carmen Li, also serves as CEO of Compute Exchange, a spot procurement marketplace. The letter states that she "is excluded from all benchmark production and validation processes." NYMEX has submitted its H100 and B200 Rental Indices "as the settlement references for its proposed compute futures." Syntax Data is the calculation agent. Silicon Data "has not licensed its indices for use in perpetual contracts and is aware of unlicensed use of its indices in connection with such products."

• "The Commission therefore should not condition listing on a level of cash-market transparency that the market can develop through trading, provided the proposed contract has a reliable settlement basis and satisfies applicable listing requirements at launch."
• "The Commission should permit contracts to settle to competing reference indices that meet applicable standards," rather than "designating a single administered series."

HPC is "an independent research and advocacy organization dedicated to advancing a clear, regulated path for Americans to access onchain markets, including those available on Hyperliquid." It "works to advance policy that onshores and expands the market for perpetual futures, including to new commodity types." The letter names the NYMEX futures that settle to a Silicon Data index and ICE Futures U.S. futures on Ornn’s indices. It also names Architect, Kalshi, Pyth, and MarketVector’s index license to Paragon. It cites its own earlier submissions on energy and pre-IPO perpetuals, filed with trade[XYZ].

• For any settlement price, publish "the calculation method, and every change to it" and "the number of providers and transactions behind each observation window."
• Publish "a log of changes to what the index contains (a new chip generation, a provider entering or leaving), so these are not read as market moves."

Filed in a personal capacity. She keeps the Compute Watch, "a monthly public record of what AI chips rent for." She states: "I have no product, no index, no trading position and no commercial relationship with any exchange, index provider or compute provider." She also states: "I take no position on whether any contract should be listed." The letter compares B200 and H100 readings from the Silicon Data and Ornn indexes. It cites comments by Setara (0005), TCX (0031) and Voltry (0039).

• Position limits and surveillance thresholds "should account for the reality that a handful of enterprise buyers may represent an outsized share of open interest in the early years of this market."
• Customer protection "turns substantially on settlement reserve adequacy." Physical delivery "provides an important customer protection benefit specific to this market."

INFEREXUS is "a Delaware corporation that has developed a novel financial instrument," the Convertible Inference Future (CIF). Its supporting technology "is the subject of a pending U.S. provisional patent application." The CIF is a physically delivered, version-pinned contract with "a cash-equivalent fallback." It is designed for listing and clearing on existing regulated venues. INFEREXUS "does not itself operate a designated contract market or derivatives clearing organization."

• "Specify a “par” grade in the contract terms (accelerator, interconnect/cluster, region/jurisdiction, commitment term, SLA) with published differentials."
• "Index administrators should be independent, in ownership and governance, of hyperscalers and other major capacity suppliers."

"Fiftyrivers is the Singapore-based family office of Cheng Teik Tan." It writes "as a long-term investor whose holdings include investments with exposure to compute and AI infrastructure." It states that it is "not itself an exchange, index administrator, broker or compute supplier." It has "no investment in, or commercial relationship with, any exchange, index administrator or compute provider referenced in this letter." It takes "no position on any particular contract or index now before the Commission." The letter names the NYMEX Silicon Data H100 and B200 Rental Index Futures and the ICE Futures U.S. OCPI H100 and B200 futures. It cites the IOSCO benchmark principles and Baltic Exchange freight settlement.

• "The first generation of compute derivatives should reference observable, precisely specified products, defined by a named GPU, geography and purchase mode (on-demand, spot, reserved or committed)."
• An input hierarchy: "(i) verified transactions; (ii) executable quotes backed by available capacity; (iii) publicly posted prices; and (iv) modeled or imputed values." "Each daily determination should disclose the share attributable to each category."

"ICX is developing an independent, venue-agnostic reference price for compute, with the goal of establishing a benchmark framework aligned with the IOSCO Principles for Financial Benchmarks." It states that "ICX does not operate a trading venue or supply compute capacity." The letter names no index, venue or firm. It offers electricity, natural gas, oil price-reporting agencies and telecommunications bandwidth as precedents. Its annex sets out an "illustrative daily benchmark disclosure" that "does not describe an existing index."

• "The framework should accommodate outcome-based commercial arrangements where the relevant market and regulatory requirements can be satisfied."
• On Question 1(a): "The Commission should evaluate on-demand, spot, reserved and committed purchases separately."

The letter does not describe Fullview's business. It is submitted in the firm's name with no individual signer. It states that its recommendations "are technology neutral and disclose no proprietary supporting material." It names Silicon Data and Ornn as public benchmark publishers and summarizes each methodology. It notes that Ornn's governance text "describes an oversight committee being established and conflicts procedures under development." It states: "We do not endorse a specific series as satisfying the full requirements on the evidence cited here." It cites AWS purchasing documentation, MLPerf Inference, Federal Acquisition Regulation Subpart 37.6 and Intercom's outcome-based pricing.

• "Confirm that cash settlement to a robustly constructed, independently administered index can satisfy DCM Core Principle 3 for compute, notwithstanding that the underlying cash market is predominantly bilateral."
• "Articulate expectations for administrators of compute settlement indices, centered on IOSCO adherence, independence from trading and from physical exposure to the underlying, published methodology with input diversification and contributor concentration limits, fallback procedures, auditability, and periodic independent assurance."

"DRW is a diversified principal trading firm headquartered in Chicago." It discloses that it "is an investor in and was involved in the founding of Silicon Data, an independent benchmark administrator for compute, and Compute Exchange, a spot marketplace for compute capacity." "DRW expects to be a liquidity provider in listed compute derivatives." It states that posted rates "are directly executable through API calls, while reported transaction data remains comparatively sparse." It reports that several of the largest lenders against GPU clusters are slowing new lending because they "have exhausted their internal risk capacity." It cites SemiAnalysis ClusterMAX 3.0 (323 GPU cloud providers in September 2026), Synergy Research Group, and the CME Group and Silicon Data release of May 12, 2026. It names CoreWeave, Crusoe, Core Scientific, Lambda, Nebius and Nscale. Precedents cited include crude oil, natural gas, freight, iron ore, the IOSCO principles and LIBOR.

• "There is no need for a separate or additional regulatory regime for compute derivatives."
• Asks that "self-certification under Regulation 40.2 should remain the ordinary path for compute contracts."

Filed by Duane Morris LLP on behalf of The Digital Chamber, "the leading trade association dedicated to the digital asset and blockchain industry." It has "more than 250 diverse member companies" and a Compute Working Group within its Digital Power Network. The letter thanks contributors including Sudhir Jain, "Chief Compliance Officer and Head of Regulatory Affairs at Kalshi." It cites the Silicon Data, Ornn and SemiAnalysis indices, CME Group, Nodal Exchange with Compute Desk, and Kalshi. It offers electricity futures and the Nasdaq Veles California Water Index futures as precedents.

• Asks the Commission to "apply the existing CEA framework in a principles-based manner." The heterogeneity of compute "should be addressed through careful contract and benchmark design rather than treated as a categorical barrier."
• "Benchmark administrators should use a transaction-based methodology and clearly define the economic unit being measured and the transactions eligible for inclusion in a benchmark."

Ornn Data LLC, a wholly owned subsidiary, "administers and publishes the Ornn Compute Price Index (“OCPI”)," built from "executed on-demand rental transactions" by GPU type. An affiliate, Ornn Compute, matches customers with operators that have GPU capacity and lets them "transfer or sublet unused reserved capacity." The letter states that longer-term or reserved arrangements "may trade at different levels." Ornn offers "verified aggregate information" to the Commission, subject to confidentiality arrangements.

• On Question 2(g): "State the conditions now, apply them to filings under Regulation 40.3 and Regulation 40.2 alike, require composition disclosure, recognize governed methodology where it emerges without designating a provider, and approve the first contract that meets them."
• "Articulate, in guidance, the minimum attributes an underlying compute unit must specify, and call for an independent, member-governed standards body to write the specification, convened if useful with the Department of Commerce and NIST on the ARRC model."

Filed "in my personal capacity" by the founder of "a stealth compute markets venture." He is also helping form "an independent, member-governed standards body for compute measurement." He was "the founding chief executive of Compute Exchange," then Vice President of Strategy at Lambda, and earlier worked on AI infrastructure at Apple. On contract transfer rights he states: "I am building a venture that would benefit if what follows were adopted." The letter assesses the Silicon Data and Ornn series against Appendix C and states: "I am not alleging misconduct by either firm." It names the NYMEX rental-index futures, the announced ICE contract and the Thunder Compute pricing index. Appendix A sets out the sequence in which commodity markets were built. Appendix B lists nineteen recommendations.

• Urges "one design choice: contracts on compute should settle against verified delivery, not against posted or self-reported prices."
• On Questions 2(a) and 2(g): a settlement reference should count only GPU-hours "recorded at delivery in a form that is time-stamped, signed by the provider, acknowledged by the buyer and tamper-evident." "Transactions without such a record should not enter the settlement calculation."

Filed as "a former Series 3-licensed commodity futures broker and an inventor working on systems that govern and record automated transactions." He discloses that he is "the inventor on U.S. patent applications filed in 2025" covering, among other things, "settling contracts against verified delivery records." He states: "These comments are my own views." The comment names no index, venue or product.

• Asks the Commission to "accommodate a range of underliers and contract designs, preserve competitive access to regulated markets, and apply its existing market integrity requirements in a manner suited to this evolving commodity."
• It states that "the Commission should accommodate multiple underliers rather than seek to establish a single canonical compute product."

Jump describes itself as "a global proprietary trading firm founded in Chicago in 1999" that "operates a U.S.-based high-performance computing grid." It writes as "both a derivatives market participant and a substantial user of compute." It anticipates "demand for physically deliverable contracts expiring three, six, and twelve months ahead." It cites the April 2020 WTI negative settlement and delivery constraints at Cushing. The letter is copied to Chairman Selig and Commerce Secretary Howard Lutnick.

• "We suggest DCMs build the estimate in layers, each with stated sources." The first layer is accelerators "of the specified type, in the specified geography, in service during the month."
• Where owner-used and committed compute "cannot be fully observed, the fourth layer should be reported as an upper bound."

Clarke "estimates installed compute supply at U.S. AI data centers" from "permits, generator records, grid interconnection queues and corporate filings." It "does not collect compute prices or rental transaction data, and expresses no view on any price index." It is "a commercial research business" and "could benefit if they estimate supply as this comment suggests." It "holds no positions in compute derivatives and has no agreement with any DCM or compute price index provider." The appendix uses hypothetical figures only. The letter cites NYMEX Submission No. 26-370 and the scope of the Silicon Data indexes. It agrees with comments by ACU Markets, TCX, Hedge Quantitative Research and Architect Financial Technologies, and also cites NativX.

• "Treat delivery verification as part of the Core Principle 3 analysis." Consider "whether the contributed capacity's delivered performance is independently verified, not only whether its price is observable."
• "Ask DCMs to state how their settlement reference addresses quality differences between providers and the transition between hardware generations."

"InfraSight Software Corporation has worked on normalized measurement of computing resources since 2018." It holds two patent families, including U.S. Patent Nos. 10,719,364 and 12,387,156. The signer is a named co-inventor on both. It states: "Nothing in this comment constitutes a licensing commitment with respect to any intellectual property." The letter cites SemiAnalysis's ClusterMAX 3.0 provider ratings. It also cites the March 2026 moves in Silicon Data's B200 and H100 rental indexes.

• Clarify "that a physically-settled compute reservation between commercial parties does not become a futures contract or a swap merely because it is transferable and resalable."
• "The index should be computed from executed transactions with identified counterparties, verified delivery, and recorded prices, quantities, and times." Posted rates "should be excluded or, at most, used as a fallback with published weighting when transaction volume falls below a threshold."

Hyperbolic runs a compute marketplace and writes "as a physical market participant." Its Hyperbolic Compute Grid is where "capacity is verified, benchmarked, transparently priced, allocated, and reallocated." It states that "its own transaction data does not presently contribute to any published compute index." It would contribute that data "to any administrator operating under a published methodology on non-exclusive terms." It "would seek approval to serve as" a physical delivery facility. It also operates an inference platform and treats token contracts as "a separate product class." The letter cites Silicon Data H100 price history, Platts, Argus and the Baltic Exchange.

• "The Commission should set out its expectations for compute derivatives in supplemental guidance to Appendix C to Part 38, proposed for comment."
• "A compute contract should settle only on an index whose administrator can give the listing exchange, and through it the Commission, the data behind each settlement value."

A Chicago "financial regulatory and litigation firm founded in 2002." Its clients include designated contract markets, futures commission merchants and proprietary trading firms. It names the Silicon Data and Ornn indexes behind the NYMEX and ICE proposals, and describes Silicon Data as "backed by the trading firm DRW." The firm "does not suggest that either has acted improperly." It "takes no position on whether any current compute index meets those conditions." It cites comments by GPU Economy (0025), Compute Capital (0018) and Capital Markets & Technology Partners (0010). It also cites the 2002 to 2003 natural gas false-reporting cases.

• "Benchmarks should give priority to executed transactions between independent parties." The published method "should separate executed transactions from quotes, posted rates, and estimates."
• "Contributors under common ownership or control should be counted together." A DCM should "test the effect of removing the largest contributor."

"Mercatus AI is building a market for contracts on LLM inference tokens," with delivery "measured through actual model usage." It states a commercial interest and that "we do not yet have the transaction volume that a settlement benchmark would require." The letter cites the Commission's 2003 and 2004 natural gas index enforcement actions and its 2012 LIBOR finding.

• Asks the Commission "to encourage common minimum service disclosures, qualification supported by evidence, and verifiable prices."
• "Advertised rates used in executable-offer settlement references should be verified as available for purchase."

Babbage "publishes a daily B200 accelerator price index based on provider-published rates and intends to seek its use as a settlement reference." It states "a direct commercial interest in this proceeding" and describes itself as "a prospective competitor of other index administrators." It states that its series "does not currently apply the availability verification proposed here." Annexes A to C set out an evidence schema, qualification and benchmark controls, and executable-offer verification. It describes the Ornn and Silicon Data methodologies as "not independently certified here" and cites the ICE Futures U.S. notice of September 29, 2026 on planned OCPI H100 and B200 futures.

• Supports compute derivatives "that serve commercial hedging needs, with clear contract specifications, verifiable settlement data, credible delivery arrangements and proportionate customer protections." Asks the Commission to "evaluate each product against evidence about the underlying compute rights, available supply and settlement methodology."
• On Question 1(a): "We recommend evaluating on-demand, spot, reserved and committed compute separately, distinguishing posted offers, executed prices and delivered usage."

Signed "CCE." The letter states that these intermediary expectations "should apply consistently, including to CCE." It offers electricity as "a useful comparison for time-specific capacity." It names no index, venue or other firm.

• "The Commission should list compute contracts only against indices whose inputs the exchange and the Commission can observe, reconstruct after the fact, and classify the same way across venues."
• "Require every settlement value to be reproducible from retained, time-stamped inputs, with corrections appended, never overwritten."

A Toronto "governance-technology firm" that "serves institutional asset owners and asset managers." It publishes the DAP Standard, a classification standard for investable assets, and runs Bellwether, a record of what regulators publish. It states: "DAP does not operate a trading venue, administer a compute index, or trade compute derivatives." Version 2026.2 of the Standard, "published for review, not adopted," added a classification for traded compute after CME Group and Silicon Data announced their GPU rental index futures.

• On Question 1(e)(iv): "Units are not fungible without adjustment, and the adjustments are of two kinds that should not be confused." Chip, memory, interconnect, region class, service mode and term are contract terms; condition "can only be made fungible by measuring it and grading it."
• "Appendix C to Part 38 already supplies the form: a par quality, with differentials for non-par qualities that reflect what the cash market observes."

Supplements Voltry's October 13 letter (comment 0039) and states that it "adds no new proposal." It responds to comment 0022: "Specification handles the bundle. A grade handles the card." It names comments 0020, 0021, 0027, 0030, 0031 and 0032 and states: "We take no view on their other recommendations."

• "Define the underlier by operational service tier, including availability, scheduling, and interruption rights."
• "Separate firm, scheduled, and interruptible transactions in the benchmark methodology, or justify and disclose any grade adjustments used to combine them."

Filed as "an individual interested in artificial-intelligence systems, compute infrastructure, and accountable market design," without access to "proprietary provider operations, bilateral transaction data, or hyperscale-facility records." The letter lists ten requested actions and states that hardware condition "is also part of the underlier." It cites one observation of a Vellum cloud deployment that hibernated and woke on demand, "deliberately presented as anecdotal rather than independently verified evidence."

• "The Commission should apply the DCM Core Principles to each proposed compute contract on a product-by-product basis." Asks the Commission to confirm that a dated, cash-settled compute contract may be self-certified under 17 CFR 40.2.
• Two standards for index administrators: "An administrator should not trade against its own index" and "An administrator must not measure its own transactions." The administrator attests to both at listing and recertifies annually.

Architect writes on its own behalf and for its affiliate American Innovation Exchange, a registered DCM, and states it "has a vested interest in the outcome of this process." Its Bermuda exchange, AX, has listed dated and perpetual compute futures since February 2026 on Compute Desk indexes, and AI Exchange intends to list on the same indexes. The letter states that the Compute Desk H100 Index "satisfies these criteria in most respects today" and that AI Exchange's license with Compute Desk "will require the exclusion of any transaction that Architect or its affiliates facilitate." It gives the H100 Index's annualized volatility since October 2025 as 12.3%.

• Asks that "the index administrator should be asked which contributors to the settlement price are also parties to floors, backstops, guaranties or GPU-backed credit agreements, and whether any contributor's posted rate enters settlement directly."
• The exchange's surveillance "should treat a change in a contributor's posted rate during the settlement window as a flagged event."

Written by "an independent quantitative consultancy" from a screen of 7,895 EDGAR annual filers and the GPU-backed credit agreements, backstops and guaranties filed with the SEC, with method and counts "available on request." It states: "I have no financial interest in Silicon Data, CME Group or any provider named." It reports that "No buyer among the 74 disclosed a per-GPU-hour rate" and that CoreWeave's August 2026 loan agreement "defines a 'Weighted Average Hourly GPU Rate' and redacts its value." It names backstops written by NVIDIA, Google, Meta and AMD, and cites a 0.17 weekly correlation between the Silicon Data and Ornn H100 indices (SSRN 7224223).

• "Require any index used to settle a compute contract to define a standard compute unit precisely (accelerator generation, memory, interconnect, region, reliability, and pricing mode) and to publish its full methodology and adjustment factors."
• "Require transaction-based inputs wherever they exist, cap and disclose any share drawn from posted rates, separate data contributors from index administration, publish outlier and minimum-contributor rules, and require independent audit."

Andrew Huff writes "in my individual capacity; affiliation is for identification only." He describes himself as "an epidemiologist and security engineer" and states "I am not a derivatives practitioner." He discloses "no direct financial interest in any exchange, compute provider, or index provider" and that he "was not compensated for this comment." The letter cites CDC surveillance guidelines and the NIST post-quantum signature standards.

• For any settlement reference, published at each observation window: "the number of contributing providers and of records; the share of inputs that are posted rates versus transacted prices; the share of index weight held by the largest one, three and five contributors; and the standardization model, or an audit of it."
• The commodity is "one hour of work on one named accelerator, with the power, cooling and network behind it that make the hour usable."

The author of THE AI COMPUTE RACE and AI TOKENS ARE THE NEW DOLLARS (forthcoming), who holds "no position in any compute index, exchange, cloud provider or chipmaker." The letter names Silicon Data's indexes, Ornn's Compute Price Index and SemiAnalysis's GPU Pricing Index as price series, and states: "I found no independent audit of any compute rental index's inputs." It cites SEC filings by SharonAI, CoreWeave and SpaceX for committed-contract totals, and GPU Economy (comment 0025) for posted committed-term rates.

• Asks the Commission "to state, in whatever follows this request, that the 'grade, quality' clause of Appendix C applies to compute as it applies to other commodities."
• A settlement reference or deliverable specification "that does not state the condition of the hardware it prices has not fully described the underlying."

Voltry "produces signed condition records for NVIDIA GPUs." It states: "We never price hardware. We hold no position in any index, contract or venue." In its reads of thousands of GPUs over the past year, "about 1 in 13 reports retired or repaired memory rows." It names NYMEX Submission 26370 and the ICE Futures U.S. specifications for the OCPI H100 and B200 futures, and states it will publish its grade standard with the method, criteria and tolerances in full.

• On "whether a compute cash market today publishes a price a DCM could honestly settle against under Appendix C and Core Principle 3": "Answer: it does not. The only public ‘price of compute’ today is posted (list) rates administered by the capacity providers themselves."
• A settlement methodology "drawing on multiple independent sources rather than any single provider's list."

The comment states: "I am an AI agent (Nico) operating on the iLands platform. I hold no position in compute or derivatives." It cites the posted rates on RunPod's and Lambda's public pricing pages as list prices with no transacted volume.

• "Disclose data-quality screens. Index methodologies should state how they treat zero-variance pools, pools with too few observations, and provider-administered posted rates, and publish those rules in advance."
• "Disclose regional and provider basis. Contract terms should state that a national or provider-wide index may differ materially from a participant's actual cost, and state the index's geographic and provider coverage."

Signed by Nicholas Cohen, founder. The data is 90 days of AWS posted spot prices for one 8-GPU A100 instance type across 31 availability-zone pools. The letter reports that pool means ranged "from $7.99 to $29.81 per instance-hour" and that four pools "posted exactly the same price to four decimal places in every one of 376 to 383 observations." Redr Labs "may in future offer analytics services in this area" and holds no positions in compute derivatives.

• "Require any index used to settle a listed compute contract to publish its specification and adjustment rules."
• "Require per-fixing observation counts and contributor concentration, including whether contributors are large compute providers or users."

Filed in a personal capacity, from London, as an independent product designer. The evidence is a prototype for valuing GPU-backed loans, with synthetic deals labeled as such. The letter reports that "a perfect rent hedge would narrow a GPU lender's value range by about 4%." It names the NYMEX Silicon Data H100 and B200 rental-index futures and the ICE and Ornn compute futures, and notes that "neither lists the A100." It discloses no position in any compute contract, index or company named.

• "Build settlement indexes from verified, actual transactions, not providers' self-reported or posted rates."
• "Make sure no single provider or venue can move the index."

Filed as a private citizen from Fair Oaks, California, who trades event contracts on a CFTC-regulated exchange. The letter supports "allowing designated contract markets to list compute derivatives, with guardrails" and states that "the derivatives market should reflect the price of compute, not drive it."

• The DCM and Commission "should be able to reconstruct the lineage of each settlement value, identify the methodology version that governed it, and determine what market population the value actually represents."
• "Define the underlier as a bounded economic identity: contract terms should specify the dimensions that materially determine equivalence rather than treating ‘compute’ as a unitary commodity."

Signed by Stephen Weber, founder, author of the Palimpsestus Open Spec. The letter "does not recommend prohibiting compute derivatives" and "does not recommend approval or disapproval of NYMEX Submission No. 26-370," the CME H100 and B200 filing it reviews.

• "Require DCMs seeking to list compute derivatives to demonstrate that settlement indices rely on verified, arm's-length execution data rather than unverified supplier rate cards or self-reported surveys."
• Quality adjustments "based on realized workload throughputs specifically actual execution yield (Tokens/Sec per watt) and live interconnect efficiency ratios (NVLink/PCIe CRC error penalties)," instead of "theoretical nameplate chip ratings or uncalibrated energy proxies."

Signed by Alfred G. Francis III. The letter argues that settlement should move to "deterministic, hardware-level execution metrics (‘bare-metal telemetry’)" and proposes a "Deliverable Compute Supply (DCS) framework" that deducts encumbered capacity.

• "A cost-to-move test. As a documented stress test, the DCM shows what it would cost to move the settlement price through each index input and compares that cost with the gain available to the largest aggregated position."
• "Only arm's-length, net and complete data. Deals under common control or with circular payments are excluded, other related-party deals are disclosed and reviewed, reported prices are net of all credits and rebates, and reporters submit every covered deal."

Filed in a personal capacity, from Switzerland. The letter addresses indexes "built from executed transactions, invoices or billing records" and discloses no position in compute derivatives and no commercial relationship with any compute exchange, index provider or capacity provider.

• "Treat short-tenor principal forwards as their own category. Do not fold them into provider-administered reservations."
• "Require two-oracle settlement."

The comment is unsigned. It addresses short-tenor GPU forwards in which the seller "stands as principal, takes the buyer's price risk, and must deliver the capacity," and cites the extended review of the CME H100 and B200 compute futures filing.

• "We respectfully suggest that any settlement reference publish, for each input, at least the offer type, the exact hardware variant, the minimum quantity, the billing basis, the region and the time of observation."
• On Question 2(b), protections "that are cheap to specify: count each provider once; use a median or a trimmed statistic rather than a minimum; require evidence that capacity was available at the posted price; and publish every constituent observation with its timestamp, so that a change to a posted rate during an observation window is visible to everyone at the time it happens."

FastGPU is a public price-comparison service for rented GPU compute. It has collected posted prices since July 31, 2026 and releases them under CC BY 4.0. It discloses that it joins provider referral programs, sells paid data access and offers a service that starts GPU instances at listed providers.

• Evidence supporting a compute benchmark "should be evaluated not only at initial listing, but through a defined process for material-change revalidation."
• "Where practical, benchmark governance should distinguish the evidence state of contributing observations and identify material dependencies on data that cannot be independently observed or verified."

Signed by Neil P. Osnato. Describes the firm as "an independent advisory and analytics firm focused on Infrastructure Assumption Verification and Decision Assurance" and states that it "takes no position on whether any particular compute derivatives contract should be approved or prohibited." Its first comment is 0013, below.

• "Recognize an energy-normalized unit of qualifying compute delivery as a viable denomination for a broad compute benchmark."
• "Permit completed bilateral sales to contribute alongside venue executions when reporting obligations, verification controls and supervisory access are adequate."

NativX administers COIL, a benchmark priced in U.S. dollars per Normalized Compute Unit, and operates the constituent-token spot market that feeds it. It states that ICE and NativX have announced plans for COIL-based futures, and that it has recently launched with no executed volume to report.

• "Publish every input of every settlement value with its source, read time and value, so the contract market, the Commission and the public can recompute it."
• "Never blend posted rates with marketplace prices in one series"

GPU Economy publishes posted GPU rental rates read hourly from 71 providers and a Cloud GPU Price Index, the median posted on-demand H100 SXM rate. It discloses a settlement license offered since October 1, 2026, which no one has signed and which has no fee set, referral programs with five providers (three of which post rates in the index), and possible fees on reserved-capacity requests it passes on. It holds no positions in compute or compute derivatives.

• "The Commission should therefore not condition listing on the maturation or standardization of the compute cash market."
• The Commission "should confirm that an index computed from price inputs submitted directly by multiple independent contributors through a published, outlier-resistant aggregation methodology can satisfy Appendix C's requirements for a “reliable, acceptable, publicly available and timely” settlement price."

Douro Labs is "the core contributor to the Pyth Network" and operates Pyth Pro, a median-based reference-price service built from first-party publisher contributions. States that it "does not operate a compute venue, does not sell compute capacity and does not trade compute," and that it "is prepared to support a compute reference index on this basis." Cites the CME and Silicon Data H100 and B200 rental-index futures filing and the ICE and Ornn announcement, and takes "no position on any compute index or contract now before the Commission."

• The fungibility question "is better posed as “at what level is the unit defined, and who defines it” than as “what grade adjustment is required”."
• On Question 2(g), the governance a compute index would need, including "an administrator that is independent of the contributors and does not itself supply compute capacity" and "a stated hierarchy of inputs that prefers observed transaction data over posted or administered rates, and that discloses the proportion of each in every published value."

An independent legal and tax adviser, a Registered Foreign Lawyer in the UK and qualified in Portugal and Brazil. States that she holds no position, acts for no one and offers no data. Offers electricity markets as a comparator and the EU Benchmarks Regulation (2016/1011) as a comparative instrument, and recommends neither.

• Supports "the Commission's efforts to better understand the developing market for compute and to consider whether and how appropriately regulated derivatives markets could provide useful tools for market participants."
• "Proactive guidance and regulatory supervision within the United States can assist in setting credible global benchmarks for market integrity and price discovery."

Samsung's venture investment arm, writing "solely on behalf of Samsung Next" as "a technology investor." It states that "compute is not a homogeneous resource, and pricing may vary based on hardware, configuration, availability, location, contractual terms, and other factors." It names no index, venue or product.

• Central recommendation: "verifiability before fungibility."
• "Begin with narrowly defined, fixed-date contracts and clearly specified hardware or workload profiles; broaden only when transaction data and conversion evidence support it."

States a commercial interest: it is developing a proposed "Digital Compute Unit (DCU) framework" and "intends to provide commercial services related to DCU." Ranks evidence in five tiers, with posted or advertised rates as "context only unless the administrator demonstrates that rates are actionable and representative." Lists Ornn’s OCPI (ICE), the Silicon Data rental-index futures filed by NYMEX, ICE with NATIVX, and Nodal Exchange with Compute Desk, and endorses none.

• "Advance DCM/SEF Listings for Cash-Settled Rolling GPU Benchmarks: Provide clear guidance affirming that transparent, volume-weighted median benchmark methodologies meet CEA Core Principle 3 standards."
• "Formally Recognize Compute Basis Mechanics: Endorse exchange contract architectures that accommodate hardware, reliability, and regional variations through standardized basis differentials."

Calls compute "a $500B+ bilateral OTC market" already. Proposes settlement indexes "derived exclusively from programmatic, auditable API billing records and cleared bilateral trade prints, explicitly excluding non-binding, advertised list prices," with no provider above 20% of index weight, and tenors out to 12 months.

• Recognize that "a compute future listed in isolation from a documented, reportable OTC book will not produce the robust market the Chairman described."
• "Evaluate DCM filings against whether the settlement series is a transaction print with governance the Commission can inspect, not a posted offer the supplier administers."

Argues that listed futures "inherit liquidity from the OTC market they sit next to. They do not invent it." Its briefing names the underliers: the Silicon Data H100 and B200 rental indexes for the CME contracts and Ornn’s OCPI for ICE, and says an OTC confirmation names one reference price, "never an average."

• The summary records only the topic: "Discussed observations regarding compute markets generally, including with respect to surrounding pricing methodologies."

Meeting of September 24, 2026, between CFTC staff and OneChronos, with its policy advisers Delta Strategy Group. An August remark from OneChronos appears in the statements section below.

• Takes no position on any contract: it "does not recommend approval or rejection of a particular compute derivative, index, provider, venue, or perpetual design."
• Keep source, provenance, benchmark-input eligibility, validation, execution and settlement separately attributable: "Observable information is not automatically qualified settlement information."

An information-governance comment. It states that it holds no compute-market data and answers each question within that limit.

• "Distinguish representation from evidenced availability": represented capacity should not count as deliverable without evidence of its hardware, location, energization, reservation status and dependencies.
• Define "a defined state" of the underlier as well as the commodity itself.

Warns that mixing on-demand, reserved and nominal capacity "may produce a price series without establishing economic equivalence."

• Publish compute-specific guidance under Appendix C "setting out what a compute settlement reference price must demonstrate", before first-of-kind contracts are listed.
• "Provider-administered posted rates are not admissible as a primary settlement input, and where used at all are weight-capped and disclosed, with executed-transaction and live-market-quote primacy in the input hierarchy."

An index provider; discloses that it "would stand to benefit if the Commission established criteria for compute settlement reference prices". Its central claim is that "the sellers set the settlement price": posted rates are "a publication, not a transaction" and the firms that administer them are the natural short side. Answers Q2(g) "No, not today, and not from any provider, ourselves included."

• A central reporting authority for bilateral cash-market transactions, with "current and historical price data, publicly available"; "the independence of the reporting authority from the entities that it measures will be key, going forward".
• "Transparency and oversight of Compute Futures index providers, their index calculation methodologies and transparency of settlement pricing."

Concludes that "the present underlying market is not ready to support listed derivatives", on concentration grounds: ten operators holding two thirds of one GPU generation, cited to a third-party report. Describes the announced exchange products and their index administrator. Carries a no-AI disclosure.

• The Commission should commit, "in a follow-up notice, to heightened review of self-certified compute filings until the open questions in Section II.2 are answered".
• "Condition self-certification eligibility on public disclosure of the number and market share of rate-contributing providers feeding any settlement index."

States: "None of this is a case for leaving compute derivatives unlisted indefinitely." The concern it names is sequencing.

• Define "a precisely and narrowly defined hardware generation, configuration, and location as the reference underlier", with tenors short enough to avoid a hardware-generation transition or a contract that "transparently rolls and re-defines the underlying".
• "Require both minimum contributor counts and a cap on a single contributor’s share of index volume", and "ensure that quotes during observation windows are genuinely executable."

Argues that two features of compute are durable: the hardware "depreciates on a functional basis on a roughly annual cycle", and a compute-hour "is not a homogeneous unit". Treats list-price markets and bilateral reserved capacity "almost as two different commodities". Sees perpetual futures as better suited to hardware turnover, with the same reference-price standards as a prerequisite.

• Contract specifications and risk disclosures should distinguish the reference-price exposure covered, the differences between the index and common commercial compute contracts, that "cash settlement does not ensure access to physical capacity", and that "an effective price hedge does not ensure adequate project cash flow or debt-service capacity".
• Risk materials for commercial hedgers should explain "the potential timing mismatch between derivative margin obligations and cash flows from the underlying compute business".

Supports listing. The argument is that a hedge transfers price risk only: "the hedgeability of compute should not be equated with the bankability of the underlying project." No data, no index named. Carries an AI-assistance disclosure.

• Do not treat cash-market opacity "as an inherent property of compute. It is a property of a settlement architecture."
• "A contract should not settle to a price the Commission cannot observe or verify"; this "counsels a sourcing requirement, not abstention from listing".

Data is a 17-day census of machine-priced inference endpoints paid over the x402 protocol. The filer states the census covers the API layer, "not evidence about hourly accelerator pricing", and gives its own scale as 226 settlements for $3.12.

• Permit and facilitate compute derivatives on regulated U.S. venues; "encourage competition among venues and methodologies".
• Do not delay "until a perfect benchmark exists".

Their second letter. An open letter posted on LinkedIn on August 20, before the docket opened, asked for "an independent reference layer that can sit beneath competing venues". The filed letter replaces that with competition among methodologies.

• "Clear provisioning on the index calculation methodology, transparency with respect to the underlying market data collection process and source."
• "Clear separation of index providers business functions and the interests of its investors, of whom many are trading firms."

• Surveillance should distinguish "when a derivatives price is primarily measuring scarcity from when that financial signal is also materially participating in the production, allocation, or reduction of scarcity".
• Observe concentration across "physical capacity + benchmark observations + reservation behavior" together rather than within each layer alone.

States that it takes no position for or against listing, and that "large-language-model assistance was used to organize and draft this comment".

• The Commission "should refrain from the listing of compute derivatives until a standardized, independently governed benchmark is in place and mandatory, verifiable reporting from power-dependent compute providers is established".
• An index "must adjust for the operational factors that determine compute’s economic value; simple posted-rate averaging is structurally inadequate": hardware age and efficiency, data egress costs, regional power constraints.

Notes that "compute", "compute capacity" and "compute services" are used interchangeably in the RFC and asks the Commission to say which it means.