Submission Pursuant to Commission Regulation 40.2(a)

Rothera Exchange and Clearing LLC · received by the CFTC 16 October 2026 · the filing (PDF)

What the wording addresses

• Payment Criterion / Settlement on Margin — every check present.
  “Payment Criterion ... encompasses the Expiration Value where the Bulls win by more than 6 points”
• Abandoned/Cancelled/Not Scheduled Game Resolution: Comprehensive Coverage, Relevant Timeline.
  “resolve based on the last fair market price as determined by the Exchange”
• Suspended Game Not Resumed Resolution: Comprehensive Coverage, Relevant Timeline.
  “does not resume from the point of suspension before the Expiration Time”
• Disqualification/Ineligibility/Vacated Result: Comprehensive Coverage, Relevant Timeline.
  “disqualified, deemed ineligible, or have the result ... vacated”

What the wording leaves open

• Source Agency Hierarchy & 'Clearly Erroneous' Override “unless the Exchange, in its sole discretion, determines such result to be clearly erroneous”
  • Independent Verification — Absent: The override determination rests on the Exchange's own sole discretion, not on any named third-party evidence or procedure.
  • Suitable Method — Absent: Unstructured sole discretion cannot reliably establish the specific factual claim ('clearly erroneous') at any defined certainty.
  • Defined Benchmark — Absent: 'Clearly erroneous' is not defined by any objective criteria or threshold.
  • Conclusive Link — Absent: no named standard - entailment cannot be assessed
  • Comprehensive Coverage — Partial: Applies only to the specific game's reported result, but which reports are reviewable is not bounded.
  • Relevant Timeline — Partial: Correction must occur 'prior to Expiration,' a bound exists but the review window itself is undefined.
  What would close it: Define objective, externally verifiable criteria for what constitutes a 'clearly erroneous' result rather than leaving it to the Exchange's unguided discretion.
• Abandoned/Cancelled/Not Scheduled Game Resolution “resolve based on the last fair market price as determined by the Exchange”
  • Independent Verification — Partial: Fair market price is 'determined by the Exchange' pursuant to Rule 7.2, whose content is not provided; the Exchange is itself the evidentiary source.
  • Suitable Method — Partial: Cannot assess whether Rule 7.2's method can establish a price with the precision asserted, since the rule text is absent.
  • Defined Benchmark — Partial: A standard is named (DCM Rule 7.2) but its content, and thus its threshold, is not supplied in this text.
  • Conclusive Link — Partial: Cannot confirm whether satisfying Rule 7.2's procedure would establish a legitimate fair market price absent the rule's text.
  • Relies on material referred to but not in the public filing.
  What would close it: Include the text of Rothera DCM Rule 7.2 defining how 'fair market price' is determined so the standard and procedure can be evaluated.
• Suspended Game Not Resumed Resolution “does not resume from the point of suspension before the Expiration Time”
  • Independent Verification — Partial: Relies on the Exchange's own determination of fair market price under Rule 7.2, text of which is not supplied.
  • Suitable Method — Partial: Cannot verify the procedure's capability to establish a defensible price absent Rule 7.2's content.
  • Defined Benchmark — Partial: Standard named (Rule 7.2) but undefined in the supplied text.
  • Conclusive Link — Partial: Entailment between meeting Rule 7.2 and a valid settlement price cannot be confirmed without its text.
  • Relies on material referred to but not in the public filing.
  What would close it: Attach or incorporate the full text of DCM Rule 7.2 so the fair-market-price methodology can be assessed.
• Delayed/Unavailable Result - Sole Discretion Resolution “it may resolve the Contract in its sole discretion”
  • Independent Verification — Absent: Resolution is based purely on the Exchange's sole discretion; no named evidence, test, or third-party procedure.
  • Suitable Method — Absent: Undefined discretionary action cannot establish any specific factual claim at a checkable level of certainty.
  • Defined Benchmark — Absent: No threshold or methodology is named for how the Exchange must resolve the contract.
  • Conclusive Link — Absent: no named standard - entailment cannot be assessed
  • Comprehensive Coverage — Absent: No defined population or data source the discretionary resolution must draw from.
  • Relevant Timeline — Partial: The 24-hour waiting period is defined, but the resolution step itself has no time or evidentiary constraint.
  What would close it: Specify an objective fallback procedure or named secondary evidentiary source for resolving the contract instead of unguided sole discretion.
• Disqualification/Ineligibility/Vacated Result “disqualified, deemed ineligible, or have the result ... vacated”
  • Independent Verification — Partial: No specific reporting source or document is named for confirming disqualification/vacatur, unlike the Source Agency hierarchy used for scores.
  • Suitable Method — Partial: No defined procedure is specified for verifying this occurrence, only the bare triggering condition.
  • Defined Benchmark — Absent: No threshold or defined criteria for what counts as 'disqualified,' 'ineligible,' or 'vacated.'
  • Conclusive Link — Absent: no named standard - entailment cannot be assessed
  What would close it: Name the specific official source (e.g., league disciplinary announcement) that will serve as evidence of disqualification or vacatur.

Every provision read

Read 31 October 2026 with Warrant Check (instrument 1.0). Labels: Present, Partial, Absent describe whether each check is found in the wording as written.

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