Regulatory posture · Pre-launch
The plan. Four tracks. Sequenced for readiness.
Wavestar Holdings LLC was founded in 2026 and is pre-launch as of May 2026. No regulatory filings have been submitted yet. This page describes the four-track regulatory plan — money transmission under FinCEN, alternative-trading-system status under the SEC, derivatives clearing under the CFTC, and exchange-grade execution under SEF/DCM rules. Spectrum and orbital filings will be coordinated in parallel through the ITU SNS and FCC IBFS. Each track is sequenced to a platform readiness milestone, with public transparency from day one.
Status
Pre-launch · no filings made
Planned tracks
FinCEN · SEC · CFTC · SEF/DCM
Coordination
ITU SNS · FCC IBFS
First filing target
FinCEN Form 107 · Month 3
The sequencing
Four tracks. One clearing house. To be filed in parallel.
We will begin as a neutral utility — permissioned transparency log, federated attestation quorum, deterministic settlement — and graduate filings as contract volume and regulator readiness align. Each track has an owner, a planned window, and will have a public docket once filing begins. Months below are measured from the formal company-operating start, not from a calendar date.
- Months 3 – 9Planned
FinCEN MSB registration · Form 107
Money-services-business registration under 31 CFR 1010. Establishes custodial-fund handling for member settlement accounts. Paired with state-by-state money-transmission licensing across 49 states plus the District of Columbia. Formal BSA programme, compliance officer, and independent review. See FinCEN MSB. - Months 9 – 18Planned
SEC Form ATS-N · Regulation ATS
Alternative Trading System filing under Rule 300 of Regulation ATS. Covers spectrum-rights trades and tokenised secondary-market instruments routed through ORCH. Surveillance obligations, fair-access terms, and disclosed operator conduct. See SEC ATS-N. - Months 18 – 30Planned
CFTC Form 7-R · Derivatives Clearing Organization
DCO registration under the Commodity Exchange Act. Wavestar assumes central-counterparty risk on ISAM forwards and ISL-capacity swaps, with a Cover-2 default fund and the full suite of Core Principles A through R. Skin-in-the-game tranche on-chain and on-balance-sheet. See CFTC DCO. - Month 36 +Planned
SEF / DCM · Swap Execution Facility & Designated Contract Market
Dual SEF and DCM registration for exchange-traded derivatives on downlink minutes, ISL capacity, propellant forwards and spectrum-hour futures. Brings pre-trade transparency, orderly-market obligations, and a self-regulatory framework. See SEF / DCM.
Spectrum & orbital coordination
Authoritative filings are the source of truth.
For spectrum-hours and orbital slots, the ITU and FCC are authoritative. Our registry is a signed mirror, reconciled nightly.
- ITU
ITU SNS coordination
Space-Network-System filings against the ITU SNS XML schema. Notifications, modifications, and Plan appendices round-tripped through our API against Bureau deadlines. Coordination outcomes are signed and anchored. Read more. - FCC
FCC IBFS reconciliation
International Bureau Filing System is the source of truth for US satellite authorisations. We reconcile the IBFS public docket against the Wavestar registry nightly; divergence is an alert, not a warning. Read more.
Governing documents
The rulebook, the recovery plan, the resilience disclosure.
Three evergreen documents bind the clearing programme together. Each is version-controlled in the transparency log; each amendment enters a public comment period before adoption.
- 01
Clearing Member Rulebook
The governing document for every participant. Contract specifications, margin methodology, default waterfall, participation standards. Amendments filed with the relevant regulator and published for public comment. Open the rulebook. - 02
Recovery & Resolution Plan
How a defaulting member is closed out. How a near-default CCP is recapitalised. How, in the limit, an orderly wind-down unfolds without taxpayer support. Read the plan. - 03
Operational Resilience
Reg SCI-aligned controls. Multi-region disaster-recovery topology. Quarterly failover exercises with regulator observation. 99.995% uptime target. Resilience posture.
Clearing houses are only as good as the transparency they operate under. We publish our rulebook, our default waterfall, and our filings docket on day one — not after the first incident.
Accountability
Public, dated, signed.
Every filing we make is published in the archive the same day. Every rulebook amendment enters a 30-day public comment period. Every annual transparency report is signed and anchored to Ethereum and Bitcoin.
- A
Transparency report
Annual public report on cleared volume, default events, rule changes, and technology incidents. Signed by the Chief Risk Officer. Read the latest. - B
Filings archive
Every filing — initial, amendment, response, withdrawal — listed with agency, date, docket number, and signed hash. Open the archive.
Engage with the programme
Early-mover membership is open.
Clearing members and observing counterparties can engage with the rulebook working group before it is frozen for CFTC filing. Design-partner terms waive fees through $10M cleared notional.