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ARTICLE · 26 JUNE 2026

10 Takeaways From The CFTC Event Contracts Proposed Rulemaking

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On June 10, 2026, the Commodity Futures Trading Commission (CFTC or Commission) published a Notice of Proposed Rulemaking (NPRM) seeking public comment on proposed amendments to CFTC Regulation...

United StatesFinance and Banking
Matthew B. Kulkin
Matthew B. Kulkin
Matthew Beville
Matthew Beville
Megan O'Flynn
Megan O'Flynn
Reade Jacob
Reade Jacob
Stephanie Odigie
Stephanie Odigie
Caroline Estey
Caroline Estey
Evan J. Goldsholle
Evan J. Goldsholle
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WHAT YOU NEED TO KNOW:

  • The CFTC recently issued a Notice of Proposed Rulemaking (NPRM) requesting comment on event contract listing standards for certain types of contracts. Public comments are due July 27.
  • The NPRM focuses on the five “Enumerated Activities” (gaming, unlawful conduct, terrorism, assassination, and war), introduces a detailed, multifactor analysis to assess when a contract “involves” one of the listed activities and whether such contracts are contrary to the public interest.
  • The WilmerHale Futures & Derivatives group provides 10 takeaways from the NPRM in this client alert.

On June 10, 2026, the Commodity Futures Trading Commission (CFTC or Commission) published a Notice of Proposed Rulemaking (NPRM) seeking public comment on proposed amendments to CFTC Regulation 40.11 and the addition of a new Appendix F to the CFTC’s Part 40 rules (Appendix F).1 The proposed amendments to CFTC Regulation 40.11 implement Section 5c(c)(5)(C) (Special Rule) of the

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