The CFTC just clarified crypto margin rules. But the headline everyone's running is wrong. The Sept 24 FAQ update addressed tokenized customer funds and blockchain records. It did NOT create a new right to pledge any token as collateral. • FCM haircut floor: 20% for non-stablecoins • $100K BTC → $80K recognized value • After 15% price drop → $68K • Shortfall: $7K if margin requirement is $75K • DCO haircuts: Set independently, reviewed monthly‌‌ The math is the story. A 20% haircut is not protection against a 20% drawdown. The discount is applied continuously to the latest market value. The cushion shrinks as price falls.‌ If the futures position also loses money, the account gets hit twice: collateral value falls while the margin requirement rises. That's the feedback loop.‌ No universal clearinghouse haircut exists. Each DCO sets its own, and can decline any token under its risk rules.‌ If the 20% haircut isn't a buffer, how do you size crypto collateral in a drawdown?