CFTC Tokenized Collateral Guidance Validates Aaim's Infrastructure

Yesterday, the CFTC launched a pilot program for digital asset collateral in derivatives markets. Acting Chairman Caroline Pham's guidance explicitly requires four things: eligible asset determination, legal enforceability of security interests, custody verification, and haircuts and valuation methodology. We built all four. Aaim's ReferenceModel protocol addresses exactly what the guidance demands. Our approach to valuation is task-specific model distillation—what an ASIC is to general computing, our domain-specialized models are to general-purpose LLMs. Purpose-built for financial valuation, not adapted from a chatbot. We started building this infrastructure in 2023 because the math was obvious. "Younger investors allocate 31% to alternatives versus 6% for older generations," said Robert Goodyear, Founder and CEO. "That wealth needs to be lendable. The traditional financial system has no mechanism to value crypto, private equity, startup shares, or tokenized assets at the speed and accuracy required for collateralized lending. We built that mechanism." The CFTC guidance requires FCMs accepting digital asset collateral to establish robust valuation frameworks accounting for volatility, liquidity risk, and real-time price discovery. Our Unified Valuation Model already calculates these parameters across 47+ asset types. We produce risk-adjusted loan-to-value ratios reflecting actual market conditions, not static haircut tables. Now look at the regulatory timeline. Community financial institutions operate under state and federal examination standards that follow CFTC and OCC precedent. Yesterday's announcement creates the regulatory cover these institutions need to deploy pledged-asset lending programs against non-traditional collateral. "We designed our architecture to slot into existing lending infrastructure rather than replace it," Goodyear continued. "Banks and credit unions don't need another platform. They need valuation intelligence they can trust for assets their current systems cannot price. That's what Aaim's ReferenceModel delivers." Our patent-pending reinforcement learning architecture continuously improves valuation accuracy through a feedback loop incorporating loan performance data. Every transaction processed across the network makes the system smarter. That compound intelligence is the moat. Aaim currently serves the credit union market exclusively through the CU WealthNext CUSO, delivering best-in-class solutions to member institutions. Expansion into community banking and mortgage platform integrations is underway. ## About Aaim Aaim provides institutional infrastructure for asset-backed lending, enabling financial institutions to verify and value the full spectrum of what their members own. Real-time valuation across 50+ asset types covers traditional securities, cryptocurrency, private equity, startup equity, real estate investments, and assets that conventional systems cannot recognize. The platform integrates with 12,000+ core financial systems and implements controls aligned with FFIEC guidance and applicable banking, securities, and consumer protection requirements.