# CFTC AI Request for Comment (2024): Request for Comment on the Use of Artificial Intelligence in CFTC-Regulated Markets

Source: https://www.bankingnewsai.com/ai-regulation/documents/cftc-ai-request-for-comment-2024
Last updated: Aug 26, 2026

On January 25, 2024 CFTC staff — the Divisions of Market Oversight, Clearing and Risk, Market Participants, and Data plus the Office of Technology Innovation — issued a Request for Comment on current and potential uses and risks of AI in derivatives markets, with comments due April 24, 2024. It adopted the Executive Order 14110 definition of AI as 'a machine-based system that can, for a given set of human-defined objectives, make predictions, recommendations or decisions influencing real or virtual environments.' The responses informed the December 2024 staff advisory.

## At a glance

| Field | Value |
| --- | --- |
| Authority | [CFTC](https://www.bankingnewsai.com/ai-regulation/cftc) |
| Type | Consultation |
| Status | Final |
| Published | Jan 25, 2024 |
| Comment deadline | Apr 24, 2024 |
| Applies to | All CFTC-regulated entities: swap execution facilities, designated contract markets, derivatives clearing organizations, swap dealers, FCMs, CPOs, CTAs, introducing brokers, and other market participants |
| Official text | https://www.cftc.gov/PressRoom/PressReleases/8853-24 |

## Key points

- Issued by the Chairman's AI Task Force, formed after Chairman Behnam's November 16, 2023 Treasury Market Conference speech
- Prompted in part by the October 30, 2023 White House Executive Order 14110 on Safe, Secure, and Trustworthy AI
- Asked about AI use in trading, risk management, compliance and surveillance, books and records, cybersecurity, and customer service
- Flagged risks of market safety, customer protection, governance, data privacy, bias mitigation, and cybersecurity
- Comment deadline: April 24, 2024 (90 days); purpose was to inform supervision and evaluate the need for guidance or rulemaking
- Chairman Behnam: the RFC would help the CFTC 'strategically identify the highest priorities and return-on-investment projects with AI use cases'

## What changed for banks

This was the CFTC's first formal, agency-wide inquiry into AI. It set the definition and use-case taxonomy the agency still uses and gave bank swap dealers and FCMs a first opportunity to shape whether AI would be governed by guidance or rulemaking; the answer, in December 2024, was guidance.

## Use cases it governs

- [Trading & capital markets](https://www.bankingnewsai.com/ai-regulation/by-use-case#trading-markets)
- [Model risk management](https://www.bankingnewsai.com/ai-regulation/by-use-case#model-risk)
- [AI governance (general)](https://www.bankingnewsai.com/ai-regulation/by-use-case#governance-general)
- [Cybersecurity](https://www.bankingnewsai.com/ai-regulation/by-use-case#cybersecurity)

## FAQ

### What definition of AI does the CFTC use?

The Executive Order 14110 definition: a machine-based system that, for a given set of human-defined objectives, makes predictions, recommendations or decisions influencing real or virtual environments. The December 2024 staff advisory reused it.

### Did the RFC lead to a rule?

No. It led to the December 5, 2024 staff advisory (CFTC Letter No. 24-17), which reminds registrants of existing obligations rather than creating new ones.

## Related documents

- [CFTC Compute Derivatives RFC](https://www.bankingnewsai.com/ai-regulation/documents/cftc-compute-derivatives-rfc-2026) — Request for Comment on the Listing of Compute Derivatives Contracts (Aug 19, 2026)
- [CFTC Innovation Task Force](https://www.bankingnewsai.com/ai-regulation/documents/cftc-innovation-task-force-2026) — Chairman Selig Announces Formation of New Innovation Task Force (Mar 24, 2026)
- [Johnson RegHub Summit Remarks (Jun 2025)](https://www.bankingnewsai.com/ai-regulation/documents/cftc-johnson-reghub-london-2025) — Keynote Remarks of Commissioner Kristin N. Johnson at RegHub Summit London 2025: Enabling AI Tools To Enhance Compliance and Surveillance (Jun 18, 2025)
- [CFTC Staff Advisory 24-17 on AI](https://www.bankingnewsai.com/ai-regulation/documents/cftc-staff-advisory-24-17) — Staff Advisory on the Use of Artificial Intelligence in CFTC-Regulated Markets (CFTC Letter No. 24-17) (Dec 5, 2024)
- [Johnson Statement on AI in Derivatives Markets (Dec 2024)](https://www.bankingnewsai.com/ai-regulation/documents/cftc-johnson-statement-2024-12-05) — Statement of Commissioner Kristin N. Johnson on Future-Proofing Financial Markets: Assessing the Integration of Artificial Intelligence in Global Derivatives Markets (Dec 5, 2024)
- [CFTC TAC Responsible AI Report](https://www.bankingnewsai.com/ai-regulation/documents/cftc-tac-responsible-ai-report-2024) — Responsible Artificial Intelligence in Financial Markets: Opportunities, Risks & Recommendations (May 2, 2024)
- [CFTC AI Scams Customer Advisory](https://www.bankingnewsai.com/ai-regulation/documents/cftc-ai-scams-customer-advisory-2024) — Customer Advisory: AI Won't Turn Trading Bots into Money Machines (Jan 25, 2024)
- [Bailey: Frontier AI and the Question of Governance (Sep 2026)](https://www.bankingnewsai.com/ai-regulation/documents/boe-bailey-frontier-ai-governance-2026) — Frontier AI and the Question of Governance — Governor Andrew Bailey (Sep 30, 2026)

Last reviewed Aug 26, 2026. Cite the official text (https://www.cftc.gov/PressRoom/PressReleases/8853-24) for the rule and this page for the summary and dates.

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