Submission Pursuant to Commission Regulation 40.2(a)
Rothera Exchange and Clearing LLC · received by the CFTC 16 October 2026 · the filing (PDF)
Summary
Warrant Check read 8 operative provisions in this filing. Across them, 26 of 48 checks are present, 13 partial and 9 absent. 1 provision has every check present. 1 statement the exchange makes to the CFTC about the filing itself (such as that it complies with the Act) is not contract terms and is left out. 1 rule on who may trade is not a settlement term and is left out.
26 present13 partial9 absentWhat the wording addresses
- Payment Criterion / Settlement Trigger — every check present.
“Chicago Bulls score over 100 total points in the Bulls vs Raptors game” - Abandoned/Cancelled/Not Rescheduled Game: Comprehensive Coverage, Relevant Timeline.
“resolve based on the last fair market price ... Rule 7.2” - Suspended Game Resumption: Comprehensive Coverage, Relevant Timeline.
“officially scheduled to resume from the point of suspension” - Shortened/Called Game - Source Agency Declares Final: Independent Verification, Suitable Method, Comprehensive Coverage, Relevant Timeline.
“Source Agency declares the gamefinal and records the total points” - Forfeit Before Game Begins: Independent Verification, Suitable Method, Comprehensive Coverage, Relevant Timeline.
“market will resolve based on the league determination of the final score” - Disqualification/Vacated Result: Independent Verification, Suitable Method, Comprehensive Coverage, Relevant Timeline.
“market will resolve based on the final result and recorded total points” - Retracted/Corrected Source Result: Independent Verification, Suitable Method, Comprehensive Coverage, Relevant Timeline.
“rely on the final corrected result published by the Source Agency”
What the wording leaves open
- Abandoned/Cancelled/Not Rescheduled Game “resolve based on the last fair market price ... Rule 7.2”
- Independent Verification — Partial: No evidence source is named for determining 'abandoned/cancelled/not rescheduled' itself; the fallback 'fair market price' mechanism is defined only by reference to an unincluded Rule 7.2.
- Suitable Method — Partial: Market price is a proxy, not a measurement of the underlying game outcome; procedure can set a settlement value but cannot establish the original claim (over/under 100 points).
- Defined Benchmark — Absent: No threshold or criteria given for what counts as 'abandoned' or 'cancelled' versus merely delayed.
- Conclusive Link — Absent: no named standard - entailment cannot be assessed
- Relies on material referred to but not in the public filing.
- Suspended Game Resumption “officially scheduled to resume from the point of suspension”
- Independent Verification — Partial: No named source for the 'officially scheduled to resume' determination; presumably league/broadcaster announcement but not specified.
- Suitable Method — Partial: An announcement of resumption could support the binary fact, but no procedure is specified to verify it.
- Defined Benchmark — Absent: No defined criteria for what 'officially scheduled to resume' requires.
- Conclusive Link — Absent: no named standard - entailment cannot be assessed
- Relies on material referred to but not in the public filing.
- Shortened/Called Game - Source Agency Declares Final “Source Agency declares the gamefinal and records the total points”
- Defined Benchmark — Partial: No explicit criteria for what makes a shortened game 'final' beyond the Source Agency's own declaration.
- Conclusive Link — Partial: Declaration of finality plausibly establishes the claim, but absent defined criteria the entailment is loosely specified.
- Forfeit Before Game Begins “market will resolve based on the league determination of the final score”
- Defined Benchmark — Partial: No stated criteria for how the league assigns a forfeit score (e.g., standard forfeit score rules not quoted).
- Conclusive Link — Partial: League determination likely establishes the claim, but without stated forfeiture-scoring rules the entailment is only loosely supported.
- Disqualification/Vacated Result “market will resolve based on the final result and recorded total points”
- Defined Benchmark — Partial: No criteria given for when disqualification/vacatur occurs or how it affects the recorded total.
- Conclusive Link — Partial: Recorded points likely still reflect the claim, but the vacatur/disqualification trigger itself has no defined standard.
- Delayed/Unavailable Result “resolve the Contract in its sole discretion”
- Independent Verification — Absent: Resolution rests on the Exchange's own sole discretion, not any named, receivable third-party evidence.
- Suitable Method — Absent: 'Sole discretion' is not a checkable procedure and cannot establish any claim at a defined level of certainty.
- Defined Benchmark — Absent: No threshold or criteria governing how discretion is to be exercised.
- Conclusive Link — Absent: no named standard - entailment cannot be assessed
- Comprehensive Coverage — Absent: No defined population/coverage for the discretionary determination.
- Relevant Timeline — Partial: A 24-hour wait period is defined, but the subsequent discretionary resolution has no time limit.
- Retracted/Corrected Source Result “rely on the final corrected result published by the Source Agency”
- Defined Benchmark — Partial: No defined criteria for what qualifies as a valid 'correction' versus a disputed revision.
- Conclusive Link — Partial: A published correction plausibly establishes the claim, but absent defined correction criteria the entailment is loosely supported.
Every provision read
Payment Criterion / Settlement Trigger
“Chicago Bulls score over 100 total points in the Bulls vs Raptors game”
Determination: Total points scored by the Bulls (or combined total) satisfies the stated comparison condition at end of regulation/overtime · Consequence: Expiration Value is set to Yes/No and the Settlement Value is paid to long or short holders
Present Independent Verification. Relies on officially reported final score from a ranked hierarchy of named third-party Source Agencies (NBA.com, ESPN, etc.) - concrete, receivable evidence, though Exchange retains sole discretion to deem a result 'clearly erroneous'.
Present Suitable Method. An official box score/final result can directly establish a point-total comparison at the precision the clause asserts.
Present Defined Benchmark. Explicit numeric threshold - 'over 100 total points' - compared against official final total.
Present Conclusive Link. Meeting/failing the >100 threshold in the official final score directly establishes the Yes/No outcome.
Present Comprehensive Coverage. Evidence (final reported game score) covers the same population as the claim - the entire specified game's total points.
Present Relevant Timeline. Covers 'conclusion of regulation time plus overtime', matching the full period the claim concerns; reporting is cut offat Expiration Time.
Abandoned/Cancelled/Not Rescheduled Game
“resolve based on the last fair market price ... Rule 7.2”
Determination: The game is abandoned, cancelled, or not scheduled/rescheduled before Expiration Time · Consequence: Contract settles on last fair market price instead of actual score, per Rule 7.2
Partial Independent Verification. No evidence source is named for determining 'abandoned/cancelled/not rescheduled' itself; the fallback 'fair market price' mechanism is defined only by reference to an unincluded Rule 7.2.
Partial Suitable Method. Market price is a proxy, not a measurement of the underlying game outcome; procedure can set a settlement value but cannot establish the original claim (over/under 100 points).
Absent Defined Benchmark. No threshold or criteria given for what counts as 'abandoned' or 'cancelled' versus merely delayed.
Absent Conclusive Link. no named standard - entailment cannot be assessed
Present Comprehensive Coverage. Applies to the whole game event, matching the claim's scope.
Present Relevant Timeline. Condition is tied to occurrence 'before the Expiration Time', matching the obligation window.
Suspended Game Resumption
“officially scheduled to resume from the point of suspension”
Determination: The game is officially scheduled to resume from the point of suspension before Expiration Time · Consequence: Contract remains open and settles on eventual final result, or else falls back to fair market price under Rule 7.2
Partial Independent Verification. No named source for the 'officially scheduled to resume' determination; presumably league/broadcaster announcement but not specified.
Partial Suitable Method. An announcement of resumption could support the binary fact, but no procedure is specified to verify it.
Absent Defined Benchmark. No defined criteria for what 'officially scheduled to resume' requires.
Absent Conclusive Link. no named standard - entailment cannot be assessed
Present Comprehensive Coverage. Covers the same single game the claim concerns.
Present Relevant Timeline. Tied to occurrence 'before the Expiration Time', matching the obligation period.
Shortened/Called Game - Source Agency Declares Final
“Source Agency declares the gamefinal and records the total points”
Determination: A Source Agency declares the game final and records the total points scored · Consequence: Market resolves based on that declared final result
Present Independent Verification. Relies on a named third-party Source Agency's declaration and recorded statistics - concrete, receivable evidence.
Present Suitable Method. An official declaration of finality and recorded points can establish the final total at the precision needed.
Partial Defined Benchmark. No explicit criteria for what makes a shortened game 'final' beyond the Source Agency's own declaration.
Partial Conclusive Link. Declaration of finality plausibly establishes the claim, but absent defined criteria the entailment is loosely specified.
Present Comprehensive Coverage. Covers the entire (shortened) game, matching the claim.
Present Relevant Timeline. Applies to points at time of stoppage, matching the truncated obligation period.
Forfeit Before Game Begins
“market will resolve based on the league determination of the final score”
Determination: A team forfeits before the game begins and the league determines a final score · Consequence: Market resolves based on the league's determined final score
Present Independent Verification. League determination is a named third-party, institutional source capable of being received/verified.
Present Suitable Method. League's formal forfeiture ruling can establish an official final score at the needed precision.
Partial Defined Benchmark. No stated criteria for how the league assigns a forfeit score (e.g., standard forfeit score rules not quoted).
Partial Conclusive Link. League determination likely establishes the claim, but without stated forfeiture-scoring rules the entailment is only loosely supported.
Present Comprehensive Coverage. Covers the whole game outcome, matching the claim.
Present Relevant Timeline. Applies to pre-game forfeiture, matching the relevant period.
Disqualification/Vacated Result
“market will resolve based on the final result and recorded total points”
Determination: A team is disqualified/ineligible or the result is vacated after the game starts but before expiry · Consequence: Market resolves based on the final result and recorded total points scored
Present Independent Verification. Relies on recorded official total points, a receivable third-party record.
Present Suitable Method. Recorded points can establish the numeric claim at the needed precision.
Partial Defined Benchmark. No criteria given for when disqualification/vacatur occurs or how it affects the recorded total.
Partial Conclusive Link. Recorded points likely still reflect the claim, but the vacatur/disqualification trigger itself has no defined standard.
Present Comprehensive Coverage. Covers the full game, matching claim scope.
Present Relevant Timeline. Window is 'after game has started but before Contract expires', matching obligation period.
Delayed/Unavailable Result
“resolve the Contract in its sole discretion”
Determination: The official result is delayed or unavailable beyond 24 hours after Expiration Time · Consequence: Exchange resolves the Contract in its sole discretion
Absent Independent Verification. Resolution rests on the Exchange's own sole discretion, not any named, receivable third-party evidence.
Absent Suitable Method. 'Sole discretion' is not a checkable procedure and cannot establish any claim at a defined level of certainty.
Absent Defined Benchmark. No threshold or criteria governing how discretion is to be exercised.
Absent Conclusive Link. no named standard - entailment cannot be assessed
Absent Comprehensive Coverage. No defined population/coverage for the discretionary determination.
Partial Relevant Timeline. A 24-hour wait period is defined, but the subsequent discretionary resolution has no time limit.
Retracted/Corrected Source Result
“rely on the final corrected result published by the Source Agency”
Determination: A Source Agency retracts/corrects a prior result and publishes a corrected final result before Expiration Time · Consequence: Exchange relies on the corrected result for settlement instead of the original
Present Independent Verification. Relies on a named third-party Source Agency's published correction - concrete, receivable evidence.
Present Suitable Method. A published correction can establish the corrected final total at the needed precision.
Partial Defined Benchmark. No defined criteria for what qualifies as a valid 'correction' versus a disputed revision.
Partial Conclusive Link. A published correction plausibly establishes the claim, but absent defined correction criteria the entailment is loosely supported.
Present Comprehensive Coverage. Covers the same single game result as the claim.
Present Relevant Timeline. Correction must be published 'prior to the Expiration Time', matching the obligation window.
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.