ISDA and Proskauer file CFTC letters on event-contract rulemaking
The International Swaps and Derivatives Association (ISDA) and law firm Proskauer each submitted letters to the Commodity Futures Trading Commission (CFTC) regarding its proposed rulemaking on prediction markets and public-interest determinations for event contracts. ISDA's July 28 letter responded to the CFTC proposal published in the Federal Register on June 12, 2026, and emphasized market integrity as event contract markets expand. Proskauer's July 29 letter recommended refinements intended to provide greater certainty for designated contract markets (DCMs) in the event-contract space.
The letters add institutional weight to a rulemaking that will decide how sports and political event contracts reach CFTC-registered platforms. ISDA's market-integrity framing gives the CFTC cover to impose stricter surveillance and capital requirements on venues like Kalshi and Polymarket. Proskauer's DCM-focused refinements suggest exchanges fear vague standards will slow approvals or invite enforcement second-guessing.
Both submissions arrive while the agency is already processing the NFL's demand for a 21-year age floor and a White House insider-trading case tied to Kalshi. The CFTC now faces compressed pressure to balance industry input, league demands, and congressional scrutiny in any final rule. The platforms that help shape that rule early will gain operational clarity; those that stay silent risk having terms imposed on them.