De Silva Law Offices backs CFTC event contract reporting rule in comment letter
De Silva Law Offices filed a comment letter with the CFTC supporting the Event Contracts data reporting rule, RIN 3038-AF73. The firm backs codifying reporting requirements for event contracts based on the agency's existing Commitments of Traders reports. The FIA trade association also responded to the CFTC's proposal on reporting fully collateralized event contracts through futures reporting frameworks. Both submissions address how event contract data should fit within established futures reporting systems.
The reporting rule would force CFTC-registered platforms like Kalshi and Polymarket to disclose event contract positions in a format the agency already uses for futures. That shifts the regulatory frame from whether event contracts are gambling to whether they behave like derivatives in practice.
For operators, compliance cost rises but so does legitimacy: a Commitments of Traders-style report treats the product as a commodity, not a wager. Traders gain transparency into concentrated positions. The CFTC gets data to defend its jurisdiction against state attorneys general who argue these contracts are bets. The comment period closes soon; final rule timing will land amid parallel court fights in New York, Wisconsin, and Utah.
The comment letter joins a running fight over how CFTC-regulated event contracts are classified, priced, and reported, coming on the heels of CFTC warnings on gambling odds, state lawsuits, and congressional pressure to restrict sports and disaster-event markets.