SOFR Academy Responds to CFTC Request Issued Pursuant to White House Executive Order 14405, Addressing How IOSCO-Aligned Benchmark Credit Spreads Can Be Integrated into Existing Regulatory Frameworks
SOFR Academy has submitted a response to the Commodity Futures Trading Commission’s Request for Information on regulations that may impede fintech innovation and competition, issued as part of the implementation of May 2026 White House Executive Order 14405, “Integrating Financial Technology Innovation Into Regulatory Frameworks.”
The submission addresses a discrete market-infrastructure question concerning derivatives that reference transaction-based benchmark credit spreads, either independently or together with SOFR.
It explains how uncertainty regarding asset-class classification, product identifiers, regulatory reporting and clearing treatment may create practical barriers for banks, borrowers, asset managers, swap dealers and market-infrastructure providers.
SOFR Academy is not requesting regulatory endorsement, designation or preferential treatment for any particular benchmark. The submission instead recommends product-neutral interpretive guidance that would enable qualifying transactions to be evaluated, reported and processed on a legally and operationally coherent basis.
Read SOFR Academy’s full submission to the CFTC (PDF)
This note is provided for informational purposes by SOFR Academy, Inc. (Sofr.org), a financial engineering firm that develops tools to support global financial market participants and public institutions. The firm’s products are designed to complement (near) risk-free rates and promote well-functioning credit markets. Headquartered in New York, SOFR Academy works with market participants, academics, and regulators to strengthen financial system resilience and transparency. SOFR Academy’s backers include 8VC, and former Goldman Sachs partner Robert Litterman who developed the Black–Litterman model together with Fischer Black in 1990. For more information, please visit www.SOFR.org.
This note is not designed to be taken as advice or a recommendation for any investment decision or strategy. Readers should make an independent assessment of relevant economic, legal, regulatory, tax, credit, and accounting considerations and determine, together with their own professionals and advisers, if the use of any index is appropriate to their goals. Neither the USD Across-the-Curve Credit Spread Index (AXI), nor the USD Financial Conditions Credit Spread Index (FXI) are associated with or sponsored by the Federal Reserve Bank of New York or any regulatory authority.
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