Milbank LLP advised Xchange Alpha LLC in connection with its designation by the US Commodity Futures Trading Commission (CFTC) as a Designated Contract Market (DCM) under the Commodity Exchange Act.
The CFTC’s order recognizes Xchange Alpha’s satisfaction of the statutory and regulatory requirements applicable to contract markets, including governance, compliance, financial resources, market surveillance and operational standards. As a DCM, Xchange Alpha is authorized to list and trade futures and other derivatives contracts on its regulated platform, subject to ongoing CFTC oversight.
The designation represents a significant regulatory milestone for Xchange Alpha. The approval was granted in 204 days, including during a federal government shutdown, making it the fastest DCM approval on record, underscoring Xchange Alpha’s preparedness and commitment to operating a transparent, compliant and well-supervised derivatives marketplace within the US regulatory framework.
The Milbank team was led by Litigation & Arbitration partner Joshua Sterling and special counsel Amanda Olear. The team also included head of Milbank’s US Corporate/M&A practice Dean Sattler and Corporate/M&A associate Richard Rowe; Litigation & Arbitration associate Brianna Borrelli; and Derivatives partner John Williams and associates Jessica Miller and Jasmynn Cobb.
