WASHINGTON, May 13, 2026 — The U.S. Commodity Futures Trading Commission’s Division of Market Oversight and Division of Clearing and Risk issued a no-action letter setting out a uniform approach to swap data reporting and recordkeeping obligations for certain fully collateralized event contracts.
Under the letter, the divisions said they would not recommend the Commission initiate enforcement actions against designated contract markets, derivatives clearing organizations, or their participants for failure to comply with specified swap reporting and recordkeeping requirements applicable to covered event contracts, subject to a series of conditions outlined in the relief.
The relief applies to fully collateralized binary payout contracts and similar variable payout contracts based on the occurrence or non-occurrence of underlying events that are listed on designated contract markets and cleared through beneficiary clearing organizations.
Growing Number of Event Contract Requests
The divisions said they had received numerous requests since 2016 from exchanges and clearing organizations seeking no-action relief from swap data repository reporting requirements for event contracts, including requests related to amendments to designation orders, changes involving clearing organizations, and other operational developments.
According to the letter, the divisions expect additional requests as more entities pursue designated contract market status for event contract trading and said the new framework is intended to streamline the process while ensuring consistent treatment across market participants.
The no-action position is intended to remove the need for the divisions to continually issue substantially similar no-action letters and extends to beneficiaries of previously issued event contract reporting no-action letters, according to the agency.
Reporting and Transparency Conditions
As a condition of the relief, beneficiary exchanges must publish transaction data including timestamps, contract details, quantity, and price information promptly after execution and must continue providing transaction-level data to the Commission under existing futures and options reporting rules.
The letter also states that covered contracts must trade as fully collateralized positions and be cleared through beneficiary clearing organizations.
Exchanges and Clearing Organizations Covered
Entities currently covered by the no-action position include KalshiEX LLC, CME Group’s Chicago Mercantile Exchange Inc., Crypto.com Derivatives North America, Polymarket US affiliates QCX LLC and QC Clearing LLC, ForecastEx LLC, Gemini Titan LLC, Bitnomial Exchange LLC, and several other exchanges and clearing organizations listed in the appendix to the letter.
