No-action postion with respect to Part 43 and Part 45 reporting, as well as related sections of Parts 38 and 39, for binary options and variable payout contracts executed on or pursuant to the rules of Railbird Exchange, LLC and cleared through QC Clearing LLC.

No-action position stating the Division will not recommend the Commission take an enforcement action against a reporting counterparty that fails to submit a swap data error correction notification with respect to an error if, at the time the reporting counterparty initially discovers and assesses the impact of an error, the reporting counterparty makes a reasonable determination that the number of reportable trades affected by the error does not exceed five percent of the reporting counterparty’s open swaps for the relevant asset class in swaps for which it was the reporting counterparty.

No-action letter stating that the Division will not recommend that the Commission commence an enforcement action against a swap execution facility (“SEF”) that does not satisfy the minimum trading functionality requirement set forth in Commission regulation 37.3(a)(2) by offering an order book as defined in Commission regulation 37.3(a)(3) (an “Order Book”), in connection with swap transactions executed on the SEF that are not subject to the trade execution requirement in Commodity Exchange Act (“CEA” or “Act”) section 2(h)(8) (“Permitted Transactions”).

No-action postion with respect to Part 43 and Part 45 reporting, as well as related sections of Parts 38 and 39, for binary options executed on or pursuant to the rules of CME and cleared through CME.

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

The Division of Market Oversight and the Division of Clearing and Risk are issuing this advisory to remind DCMs and DCOs of certain Core Principle and regulatory obligations under the Commodity Exchange Act and Commodity Futures Trading Commission regulations related to controls designed to address market volatility.