FalconX Bravo has asked the SEC and CFTC to classify cash-settled perpetuals tied to a single security or narrow-based security index as security-based swaps when they fall outside the agencies’ joint security-futures framework. The proposal, submitted Aug. 12, also covers comparable contracts offered through DeFi protocols, including single-stock perpetuals, but excludes Bitcoin perpetuals and crypto perpetuals generally. FalconX also seeks to raise Rule 18a-10’s combined-notional threshold for alternative compliance from 10% to 49%, while retaining the fixed-dollar cap, SEC registration and oversight, and uncovered requirements. Independent researcher Amadeus Brandes proposed retaining the existing mixed-swap process in an Aug. 21 comment. The comment window closes Aug. 24, but neither submission constitutes agency policy, authorizes a product or commits either regulator to rulemaking.