This letter serves to amend CFTC Letter No. 14-130, which permits Victoria University of Wellington, New Zealand (“Victoria University”) to operate a not-for-profit market for the trading of event contracts and the offering of such event contracts to U.S. persons (“the Market”). The Market has been operating under the trade name “PredictIt.” All terms of CFTC Letter 14-130 not amended by this letter shall remain in effect.

Extension of no-action position with respect to Part 45 for entities submitting swaps for clearing by derivatives clearing organizations (DCOs) operating consistent with CFTC exemptive orders or no-action positions provided by CFTC staff.

After considering the request of MIAX Futures and related facts and circumstances, the Division believes that temporary no-action positions are warranted to provide participants in the HRSW Options market with a means to trade out of or offset their open positions in the September 2025 and December 2025 expirations when electronic trading is no longer available.

Extension of Time-Limited No-Action Position from Certain Requirements of Part 45 and Part 46 of the Commission’s Regulations, for Certain Swap Dealers and Major Swap Participants Established under the Laws of Australia, Canada, the European Union, Japan, Switzerland or the United Kingdom

No-action positions in relation to the Commission’s swap clearing and uncleared swap margin requirements in connection with a court-supervised transfer, pursuant to the laws of the United Kingdom, of certain legacy swaps from Credit Suisse International to UBS AG London Branch following the merger of UBS Group AG and Credit Suisse Group AG.

No-action position for swap dealers and major swap participants relating to the requirement to disclose a pre-trade mid-market mark to the swap counterparty under Commission Regulation 23.431(a)(3)(i).

The conditional no-action position with respect to Regulation 39.13(g)(8)(iii) contained in CFTC Letter No. 19-17 is now further extended until July 21, 2025.

Based on the representations presented by KRX to the Division as discussed above, the Division will not recommend that the Commission take enforcement action against KRX with respect to the offer or sale of the Contracts to persons located within the United States while the Commission’s review of KRX’s forthcoming request for certification of the Contracts pursuant to Commission Regulation 30.13 is pending.

The Divisions will not recommend that the Commission initiate an enforcement action against Kalshi, Klear, or their participants, for failure to comply with Commission regulations 38.8(b), 38.10, 38.951 (only to the extent that regulation 38.951 requires compliance with Part 45 of the CFTC’s regulations), and 39.20(b)(2), as well as the applicable provisions of Parts 43 and 45 of the CFTC’s regulations, or the requirements of the relevant CEA provisions pursuant to which the Relevant Regulations were promulgated, with respect to Kalshi Contracts, subject to certain conditions.