The Commodity Futures Trading Commission's Market Participants Division issued an interpretation and a no-action position in response to Coinbase Financial Markets Inc.'s plan to offer certain digital commodity derivatives listed on its affiliated foreign board of trade, Deribit FZE. The staff letter confirms that the perpetual contracts described may be categorized as foreign futures under Commission Regulation 30.1. It also states that, subject to specified conditions, staff will not recommend enforcement action if Coinbase Financial Markets, as a registered futures commission merchant, posts customer-owned digital commodities and payment stablecoins with its foreign broker affiliate as margin for foreign futures and foreign options positions on that affiliate foreign board of trade. The interpretation aligns with the Commission's order approving the KalshiEX LLC BTCPERP futures contract. The no-action relief covers arrangements in which the foreign broker has obtained a right of re-use over the customer-owned assets transferred as margin.