De Silva Law Offices backs CFTC event contract reporting rule in comment letter
De Silva Law Offices filed a comment letter backing a CFTC rule to require event contract data reporting modeled on the agency's existing Commitments of Traders framework. The firm endorsed RIN 3038-AF73, which would codify reporting requirements for fully collateralized event contracts. The FIA trade association also submitted comments on how these contracts should be reported under existing futures regimes. A CFTC official separately noted at an August 20 innovation conference that the agency has never instituted a comprehensive regulatory framework for event contracts despite decades of trading.
The CFTC now has industry backing for a reporting regime that would treat event contracts like traditional futures. Kalshi and Polymarket would face granular position disclosures modeled on Commitments of Traders reports, exposing trader concentration and market size to public scrutiny. That transparency could chill institutional participation or invite congressional attention to contract popularity.
The timing is acute: the agency is tightening marketing rules and fighting states in court over preemption, so a new reporting mandate lands while platforms are already defensive. FIA's parallel comments signal exchange membership expects compliance costs to rise. The CFTC official's admission that no comprehensive framework exists suggests the agency may pair reporting with broader rulemaking, extending the regulatory runway before final requirements take effect.
The comment letter joins a CFTC enforcement push that includes warnings on gambling-style marketing and a broader crackdown on how prediction market platforms present their contracts.