Author Archives: Hilary Allen

Statement of Opposition to HFSC’s Digital Asset Regulation Discussion Draft

By | June 27, 2023

The following letter was submitted to the House Financial Services Committee for inclusion in the record of a June 13, 2023, hearing titled: “The Future of Digital Assets: Providing Clarity for the Digital Asset Ecosystem.” The hearing was held to discuss a recently introduced bill that would provide a statutory framework for digital asset regulation.… Read More »

Non-Intermediate Clearing of Crypto Derivatives on Margin is a Bad Idea

By | May 12, 2022

The following is an edited comment letter that was submitted to the Commodity Futures Trading Commission (CFTC, or Commission) on May 11th in regards to the Commission’s request for comment on FTX’s request to amend their derivatives clearing organization order to permit it to clear non-intermediated, margined products. All submitted comments can be viewed here. We are law professors… Read More »