Regulatory Alerts2020-06-24 | 2020-11827Retail Commodity Transactions Involving Certain Digital Assets
The Commodity Futures Trading Commission issued final interpretive guidance clarifying the 'actual delivery' exception for retail commodity transactions involving digital assets serving as a medium of exchange. The guidance establishes that actual delivery occurs when a customer has the ability to take possession and control of the entire quantity of the commodity and use it freely in commerce no later than 28 days after the transaction. This final rule finalizes the proposed interpretation with revisions based on public comments and judicial precedents regarding the transfer of possession and control.
Share