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CFTC Staff Issues No-Action Letter Regarding Event Contracts

Date 07/08/2025

The Commodity Futures Trading Commission’s Division of Market Oversight and the Division of Clearing and Risk today announced they have taken a no-action position regarding swap data reporting and recordkeeping regulations for event contracts in response to a request from the Railbird Exchange, LLC, a designated contract market, and QC Clearing LLC, a derivatives clearing organization.

The divisions will not recommend the CFTC initiate an enforcement action against either entity or their participants for failure to comply with certain swap-related recordkeeping requirements and for failure to report to swap data repositories data associated with binary option transactions and variable payout contract transactions executed on or subject to the rules of Railbird and cleared through QC Clearing, subject to the terms of the no-action letter. 

The no-action letter applies only in narrow circumstances and is comparable to no-action letters issued for other similarly situated designated contract markets and derivatives clearing organizations. 

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