The CFTC, Prediction Markets and Event Contracts

Appendix A

Date

Event

Jun. 30, 2017

CFTC Staff Letter 17-31: DMO and DCR provide no-action relief to Nadex (DCM and DCO) from the SDR Regulations for fully-collateralized binary option event contracts and spread event contracts executed on and cleared by Nadex. Conditions include that no participant clears through a third-party clearing member. CFTC Staff Letter 17-32: DMO and DCR provide no-action relief to Cantor Futures Exchange (DCM) and Cantor Clearinghouse (DCO) from the SDR Regulations for fully-collateralized binary option event contracts executed on Cantor Futures Exchange and cleared by Cantor Clearinghouse. CFTC Staff Letter 21-11: DMO, DCR and the Division of Data provide no-action relief to KalshiEX LLC (DCM) and LedgerX LLC (DCO) from the SDR Regulations for fully-collateralized binary option event contracts executed on Kalshi and cleared by LedgerX.

Jun. 30, 2017

Apr. 22, 2021

June 10, 2024

89 FR 48968: CFTC proposes amendments to CFTC Regulation 40.11.

Jul. 12, 2024

CFTC Staff Letter 24-09: DMO and DCR provide no-action relief to ForecastEx LLC (DCM and DCO) from the SDR Regulations for fully-collateralized binary option event contracts. CFTC Staff Letter 24-12: DMO and DCR provide no-action relief to LedgerX LLC d/b/a MIAX Derivatives Exchange (MIAXdx) (DCM and DCO) from the SDR Regulations for fully-collateralized binary option event contracts executed on or pursuant to MIAXdx’s rules. Conditions include that no participant clears through a third-party clearing member. CFTC Staff Letter 24-15: DMO and DCR expand the scope of Staff Letter 21-11 to include Kalshi Klear LLC as a DCO covered by the no-action position related to the SDR Regulations.

Sep. 4, 2024

Oct. 4, 2024

Jan. 17, 2025

CFTC issues an amended order of designation for KalshiEX LLC as a DCM, removing the prior non-intermediation condition.

March 2026 / Page 1

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