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Comment for General CFTC Request for Comment on Trading and Clearing of Derivatives on a 24/7 Basis

  • From: Christopher Enitan
    Organization(s):
    Nebula Forge UG

    Comment No: 74726
    Date: 4/24/2025

    Comment Text:

    In consideration for the foreseeable increase in trade volume especially from market participants from other active timezones, is there a proportional increase in risk of security, maintenance, backup rotations, upgrades and the labor requirements to properly monitor this.

    Furthermore, the necessity of increased relationship with brokers and their subjective business dependencies would need further considerations.

    Typical approaches and solutions in other digital industries (Entertainment) involve considerable intensive contingency plans, increased labor requirements, restructuring of technical solutions and ultimately cost considerations.

    I suggest and elaborate in the attached document, a phase-based and incremental approach to this; inline with the selective approach on asset types.

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