The Division of Market Oversight (“Division”) of the Commodity Futures Trading Commission (“Commission”) is issuing this letter in response to a no-action letter request from Coinbase Derivatives, LLC (“COIN”), a designated contract market (“DCM”), submitted pursuant to Commission regulation 140.99. COIN seeks a no-action position with respect to certain requirements under Commodity Exchange Act (“CEA”) Section 5(d)(20), and Commission regulation 38.1051(c) addressing backup facilities.