The WFE has published a response to the CFTC’s Request for Comment on Trading & Clearing Derivatives on a 24/7 Basis. The paper outlines the operational and structural considerations necessary for extended or continuous markets, and argues that while such operations introduce novel challenges such as constant system availability, real-time risk management, and staffing requirements, they may also reduce systemic risks by preventing migration to unregulated, opaque trading venues.
The response identifies specific areas where 24/7 models differ from current practices, particularly in terms of liquidity fluctuations, margining outside of banking hours, and continuous price formation. It discusses the need for enhanced operational resilience, including mirrored systems, real-time surveillance, and failover mechanisms, and also notes that broader infrastructure must evolve in parallel to support extended operations.