US stock perpetuals win clearance, but stock-market halts can still block exits

The CFTC said on Nov. 3 that US stock perpetual futures could begin trading on eligible regulated exchanges. These contracts track share prices without a fixed expiration date, but holders remain subject to stock-market halt rules that can interrupt an exit.

Chairman Michael Selig said the contracts had been deemed approved under Regulation 40.3. Eligible venues are designated contract markets also notice-registered with the SEC as securities exchanges, bringing the products into the agencies' joint security-futures framework.

Permission and access are separate

Kalshi says it now offers single-stock perpetuals, with no expiration date, but explicitly warns that they do not trade 24/7. Markets follow schedules with regular closures, and customers cannot open or close positions while a market is closed. Access requires a perpetuals application and educational tutorial; leverage depends on the stock and position size.

For Coinbase, the individual CFTC product record still displayed “Approval Pending” when checked Nov. 4, while the SEC's rulemaking index marked its separate customer-margin proposal withdrawn. Those entries do not overturn the Nov. 3 announcement, but neither establishes a Coinbase customer launch or final terms.

Coinbase's September filing describes cash-settled futures on stocks and ETF shares, without ownership of the underlying shares. Its product submission uses AAPL as a representative specification and makes listing contingent on approvals. Its proposed controls apply to Coinbase's design, rather than setting the terms for every venue.

Securities industry trade group SIFMA's Nov. 2 letter sought further review of proposals from Bitnomial, Coinbase, Kalshi and Nadex, raising concerns about manipulation, thin-liquidity trading and classification.

Under the security-futures halt requirement, a future on a single security must stop trading whenever that security is under a regulatory halt, subject to an applicable exemption. The agencies' joint-rule explanation says exemptions from both sets of requirements are needed.

These controls protect investors by allowing information to circulate and markets to regain order. Their immediate consequence is that an affected holder cannot use a closing trade in the halted contract to reduce exposure.

Buying or selling the same stock, or using its options, cannot be assumed to solve that problem: those markets generally honor the underlying regulatory halt too. A broader-market instrument might remain available during a company-specific interruption, but it leaves company-specific risk.

A venue-only derivatives outage presents a different case. If the cash market or another relevant instrument remains open and accessible, a separate trade may offset some exposure. That is a conditional hedge, dependent on access and liquidity, and it leaves the original perpetual open.

Coinbase's filed Rule 1207 would subject its contracts to US equity market-wide circuit breakers and coordinated halts, while also allowing restrictions for corporate actions, market disruptions and index-price or data outages. Reopening would follow the end of the halt condition and an exchange determination that resumption meets investor-protection and orderly-market requirements. The underlying stock reopening would not, by itself, promise an immediate futures exit.

Which market has stopped?

The affected future must halt with its stock, subject to an applicable exemption. Same-stock and options exits are generally interrupted too.

A separate hedge may offset exposure, but it leaves the original perpetual open.

Regulatory halts are subject to applicable exemptions. Hedge access and liquidity are conditional. Coinbase filings support the mechanism analysis, not a claim of current Coinbase launch or operative terms. Geometry is not time, price or probability.

Sources and evidence

Sources

1. Kalshi stock-perpetual customer guidance
2. CFTC security-futures halt requirements
3. SEC/CFTC joint halt-rule explanation
4. Coinbase filed security-futures framework
5. Coinbase filed product submission

Supporting facts

• Kalshi says it now offers single-stock perpetual futures with no expiry, but markets follow schedules with regular closures; traders cannot open or close positions while a market is closed. [1]
• Kalshi says stock-perp funding is calculated once daily at 4 p.m. Eastern, access requires an application and educational tutorial, leverage depends on the stock and position size, and adverse moves may trigger liquidation if maintenance margin is breached. [1]
• Under the security-futures trading-halt requirement, a single-security future must halt when its underlying security is in a regulatory halt, subject to any applicable regulatory exemption; the joint-rule explanation says exemptions from both agencies are needed to avoid both sets of requirements. [2] [3]
• Regulatory halts are investor-protection measures for news dissemination and orderly markets; the same-stock cash market and related options generally also halt, so they cannot be assumed to provide an immediate exit from that interruption. [2] [3]
• For a venue-specific derivatives outage while the underlying market remains open, a trader may be able to offset price exposure with an accessible stock or another open instrument, but that hedge does not close the original contract; a broad-market hedge leaves company-specific risk. [4] [2] [1]
• A pause in funding calculation does not itself settle an open perpetual or guarantee execution at its reference price; absent trading, holders can still face a different reopening price and margin pressure. [4] [5] [1]

Method

Conceptual, nonquantitative diagrams map source-backed interruption mechanics. Selectable scenarios change market status and the conditional alternate route together. They are explanations, not reports of particular outages.

Scope

Regulatory halts are subject to applicable exemptions. Hedge access and liquidity are conditional. Coinbase filings support the mechanism analysis, not a claim of current Coinbase launch or operative terms. Geometry is not time, price or probability.

Infographic by CryptoSlate

Funding and price fallbacks leave the position open

Funding payments are cash adjustments on open positions. Changing their calculation is separate from executing a closing trade.

Coinbase's September product submission describes hourly funding and proposes trading from Sunday at 8 p.m. through Friday at 5 p.m. Eastern. Its index design checks input freshness, removes outliers, uses median pricing and falls back to a reference when inputs are insufficient.

The filed framework permits substitute price inputs and allows funding to be suspended, deferred or modified during disruption. The product appendix specifies no funding-rate publication for an entire hour in which trading is closed, paused or halted.

Neither a fallback price nor a funding pause closes the position or guarantees a trade at the reference value. Kalshi separately uses daily funding at 4 p.m. Eastern and warns that closures can leave holders facing a different reopening price. Adverse moves may push an account below maintenance margin and trigger liquidation.