Two days after the Senate blocked the Clarity Act, the CFTC filed a prerule-stage regulatory action with the White House Office of Information and Regulatory Affairs under docket RIN 3038-AF80, titled Regulation of Crypto Asset Transactions and Regulation of Crypto Asset Markets. A prerule filing is earlier in the process than a proposed rule, meaning formal public comment and implementation are still a significant distance away, but the filing confirms the CFTC is moving independently to assert jurisdiction over crypto markets rather than waiting for Congress.
For Armada's crypto desk, CFTC rulemaking over crypto asset transactions could directly affect how BTC, ETH, and SOL — all accepted as repo collateral — are classified and regulated. If the CFTC establishes these as commodities under its jurisdiction, it provides more regulatory clarity than the current vacuum but may also impose reporting, margin, or counterparty requirements on crypto repo transactions. Legal counsel should monitor RIN 3038-AF80 and evaluate whether a CFTC commodity framework would affect Armada's MRA documentation, haircut policies, or counterparty eligibility.