CFTC Issues Blanket No-Action Letter Cutting SDR Reporting for Event Contracts
The CFTC‘s Division of Market Oversight and Division of Clearing and Risk jointly announced the position. The two divisions said they will not recommend enforcement action against designated contract markets, derivatives clearing organizations, or their participants for failing to report event contract transaction data to swap data repositories.
The no-action relief also covers recordkeeping requirements that would otherwise apply under existing swap regulations. The CFTC made clear the position applies only within the terms outlined in the letter issued May 13.
Regulators explained that the decision came in response to repeated requests from DCMs and DCOs to list and clear event contracts. Multiple operators had filed individual requests seeking similar relief, leading the agency to consolidate its approach.
The divisions disclosed that they expect more requests to follow. Some of those requests are expected to ask for modifications to earlier no-action positions, accounting for changes to DCM designation orders, new DCOs entering the space, and other market developments.
By issuing a single blanket position, the commodities and derivatives regulator aims to reduce administrative burden on both regulators and market participants. The structure removes the need for the agency to issue repetitive individual letters each time a new entity seeks the same relief.
The new framework covers all entities that previously received no-action letters on event contract data reporting. Those prior beneficiaries remain covered without needing to file again.
Entities that want to list or clear similar contracts going forward can request inclusion in the letter. If the divisions approve, the requester’s name gets added to an appendix attached to the CFTC letter.
The CFTC stated that the appendix approach ensures consistent treatment between new applicants and those that received earlier individual letters. Regulators described the goal as streamlining the process for addressing future requests.
Prediction markets have drawn increasing attention from federal regulators over the past two years. Platforms like Polymarket and Kalshi allow users to trade on the outcome of political, economic, and other real-world events, which have pushed regulators to clarify where event contracts fit under existing derivatives law.
The no-action letter does not change the underlying legal status of event contracts. It narrows the scope of reporting obligations the CFTC will actively enforce while the broader regulatory framework continues to develop. Last month, CFTC Chairman Michael Selig told lawmakers that the regulator uses Microsoft AI tools to monitor prediction markets.
Operators that fall outside the terms of the letter are not covered and cannot assume identical protection. The CFTC said entities in that position need to file a direct request to be added to the appendix.
The letter positions the CFTC as the primary federal regulator managing the compliance structure for prediction markets operating in the United States, at least for now. The letter arrives as dozens of states clash with the CFTC in court over who holds regulatory authority across the prediction market sector.
