Six Index Futures Are About to Lose Their Expiry Dates. The Relief That Allows It Runs Out October 20.

On October 5 the CFTC's Division of Market Oversight issued Staff Letter No. 26-29, giving designated contract markets no-action relief to convert existing perpetual-style broad-based security index futures into true perpetual futures — that is, to delete their expiration dates. The relief takes effect immediately on publication of the amendments, and the no-action positions expire on October 20, 2026.

The mechanics are narrow and the window is short. What makes the letter worth reading is what it says about how these contracts were built in the first place.

What the exchange asked for

The request letter was sent on October 1 by Jane Downey, Chief Regulatory Officer of Coinbase Derivatives, LLC, to DJ Hennes, Acting Director of the Division of Market Oversight. Coinbase Derivatives is a designated contract market. It asked staff not to recommend enforcement if it amended six contracts to remove their expiry dates with immediate effect, which would mean waiving the 10-business-day waiting periods in CFTC Regulations 40.6(a)(3) and 40.6(b)(1), and also asked that staff not recommend a stay of the amendments under Regulation 40.6(c)(1).

The six contracts named in the request are US500 Index Perp Style Futures, Tech100 Index Perp Style Futures, Defense10 Index Perp Style Futures, AI10 Index Perp Style Futures, China10 Index Perp Style Futures and Coin50 Perp Style Futures. The first of them began trading on July 21, 2025.

Why the expiry dates were there

According to the request, the contracts carry a stated expiry far in the future — 2030 is the example given — and that date was included in order to meet existing guidance on what counts as a future. The economics of the contract are driven instead by a funding-rate mechanism, which creates a constant incentive for the contract price to converge with the underlying spot market. On the exchange's account the remote expiry does no economic work.

That is the crux of the argument. A funding rate is the device crypto exchanges invented to keep an expiryless contract tethered to spot; borrowing it for an equity index future leaves the expiry date as a formality. Coinbase Derivatives says the contracts are typically held for short periods and are not traded for delivery at expiry, so they already function as perpetuals, and that removing the date would spare holders the need to roll positions into new long-dated futures. It argued that a 10-day delay would create confusion, because similar products on other designated contract markets would carry different expiry terms in the meantime, and that it would place the exchange at a competitive disadvantage.

The conditions attached

• Solicit feedback from market participants holding open positions
• Give advance notice and an opportunity to exit positions
• Provide appropriate risk disclosures
• Make no other material changes to the contract terms
• File the amendments under CFTC Regulation 40.5 or 40.6
• Certify compliance with all of the conditions

The request letter also refers to a separate submission by Kalshi for US500 perpetual futures referencing the MerQube US Large Cap Index, cited as context for the Commission's policy statement in this area.