Will England win the first One Day International between England and Pakistan on May 15, 2027?
Railbird Exchange, LLC · received by the CFTC 21 October 2026 · the filing (PDF)
Warrant Check read 9 operative provisions in this filing. Across them, 40 of 54 checks are present, 10 partial and 3 absent. 2 provisions have every check present. 1 rule on who may trade is not a settlement term and is left out.
40 present10 partial3 absent1 not assessedThe payout rule here is “Payout Criterion (Official Result)”: the rule that says what makes the contract pay Yes or No. The other 8 rules are fallback rules: what happens if the event is cancelled or delayed, the data goes missing, or the result is challenged.
| Topic the staff letters raise | Payout rule | Fallback rules |
|---|---|---|
| Settlement source identified | Addressed | 5 of 8 addressed |
| Settlement method described | Addressed | 5 of 8 addressed |
| Covers every case it applies to | Addressed | 7 of 8 addressed |
| Timing set | Addressed | 7 of 8 addressed |
| Terms in the public filing | Kept elsewhere | 4 of 8 in the filing |
What the wording addresses
- Payout Criterion (Official Result): Independent Verification, Suitable Method, Defined Benchmark, Conclusive Link, Comprehensive Coverage, Relevant Timeline.
“resolves YES if [entity] is declared the winner of [event]” - Abandoned Match – No Official Result: Comprehensive Coverage, Relevant Timeline.
“Resolves to the last fair market price, as determined by the Exchange” - Tie – No Winner Determined: Independent Verification, Suitable Method, Defined Benchmark, Conclusive Link, Comprehensive Coverage, Relevant Timeline.
“Each team's Contract resolves at $0.50” - Source Agency Reporting Delay: Independent Verification, Suitable Method, Defined Benchmark, Conclusive Link, Comprehensive Coverage, Relevant Timeline.
“does not report the relevant result within 48 hours” - Mutually Exclusive Set Settlement — every check present.
“aggregate payout across the Mutually Exclusive Set equals the Contract Size” - Position Accountability Reporting: Independent Verification, Suitable Method, Defined Benchmark, Conclusive Link, Comprehensive Coverage, Relevant Timeline.
“provide the Exchange with information regarding the nature” - Unconditionally Determined Outcome: Comprehensive Coverage, Relevant Timeline.
“settles based on that determination regardless of any subsequent event” - Incorrect Listed Schedule — every check present.
“Settles based on the actual event as scheduled”
What the wording leaves open
- Payout Criterion (Official Result) “resolves YES if [entity] is declared the winner of [event]”
- Relies on material referred to but not in the public filing.
- Abandoned Match – No Official Result “Resolves to the last fair market price, as determined by the Exchange”
- Independent Verification — Partial: Absence of an ICC report is checkable, but the resulting 'last fair market price' is the Exchange's own undefined determination, not third-party evidence.
- Suitable Method — Partial: Non-reporting can establish 'no official result' but cannot itself establish what the settlement price should be.
- Defined Benchmark — Partial: Completion Window is a named time threshold, but 'last fair market price' has no defined calculation method.
- Conclusive Link — Partial: Meeting the no-result/time condition establishes abandonment but does not entail any specific, ascertainable price.
- Tie – No Winner Determined “Each team's Contract resolves at $0.50”
- Relies on material referred to but not in the public filing.
- Clearly Erroneous Result Referral “the matter is referred to the Market Outcome Review Process”
- Independent Verification — Absent: Trigger is the Exchange's own determination ('if the Exchange determines'), not a named external evidentiary source.
- Suitable Method — Absent: 'Clearly erroneous' has no defined test or procedure to establish it at any level of certainty.
- Defined Benchmark — Absent: No threshold or spec is named for what counts as 'clearly erroneous'.
- Comprehensive Coverage — Partial: Applies to 'a reported result' for this contract, but no defined population/criteria for review triggers.
- Relevant Timeline — Partial: No time bound given for when this determination must be made relative to settlement.
- Relies on material referred to but not in the public filing.
- Source Agency Reporting Delay “does not report the relevant result within 48 hours”
- Relies on material referred to but not in the public filing.
- Position Accountability Reporting “provide the Exchange with information regarding the nature”
- Relies on material referred to but not in the public filing.
- Unconditionally Determined Outcome “settles based on that determination regardless of any subsequent event”
- Independent Verification — Partial: No named external evidence/procedure for verifying 'certainty'; appears to rest on an evaluative judgment.
- Suitable Method — Partial: The conceptual test (certainty regardless of further activity) lacks a concrete applied procedure.
- Defined Benchmark — Partial: A definition is given but it is conceptual/elastic rather than a fixed, checkable threshold.
- Conclusive Link — Partial: If genuinely met the definition would entail settlement, but looseness of the standard weakens confidence.
Every provision read
Payout Criterion (Official Result)
“resolves YES if [entity] is declared the winner of [event]”
Determination: [entity] is declared the winner of [event] in the Official Result reported by the Source Agency · Consequence: Contract resolves YES and Settlement Value is paid to holders of long positions
Abandoned Match – No Official Result
“Resolves to the last fair market price, as determined by the Exchange”
Determination: [event] starts and is abandoned, and no official result is declared within the Completion Window · Consequence: Contract resolves to the last fair market price as determined by the Exchange
Tie – No Winner Determined
“Each team's Contract resolves at $0.50”
Determination: [event] concludes in a tie and no winner is determined under official playing conditions · Consequence: Each team's Contract resolves at $0.50
Clearly Erroneous Result Referral
“the matter is referred to the Market Outcome Review Process”
Determination: the Exchange determines that a reported result is clearly erroneous · Consequence: matter is referred to the Market Outcome Review Process pursuant to Rule 7.1
Source Agency Reporting Delay
“does not report the relevant result within 48 hours”
Determination: the Source Agency does not report the relevant result within 48 hours of Conclusion · Consequence: Contract is referred to Market Outcome Review Process and may resolve to last fair market price
Mutually Exclusive Set Settlement
“aggregate payout across the Mutually Exclusive Set equals the Contract Size”
Determination: one or more Contracts in the Set resolve to a value other than $0 or full Contract Size · Consequence: remaining Contracts resolve so aggregate payout across the Set equals the Contract Size
Position Accountability Reporting
“provide the Exchange with information regarding the nature”
Determination: a Member holds or controls aggregate positions at or above the 125,000-contract accountability level · Consequence: Member must provide position/strategy/hedging information and may be instructed not to increase/decrease positions
Unconditionally Determined Outcome
“settles based on that determination regardless of any subsequent event”
Determination: the Contract outcome is Unconditionally Determined at some point before Conclusion · Consequence: Contract settles based on that determination regardless of subsequent events
Incorrect Listed Schedule
“Settles based on the actual event as scheduled”
Determination: the start date/time displayed for [event] by a third party was incorrect · Consequence: Contract settles based on the actual event as scheduled by the governing body
Read 3 November 2026 with Warrant Check (instrument 1.0). Labels: Present, Partial, Absent describe whether each check is found in the wording as written. Not assessed: Conclusive Link cannot be judged where no Defined Benchmark is named; that follows from the missing benchmark and is not a separate gap.
Drafting a certification?
Have the draft read through the same lens before it is filed: privately, with nothing published. You get what the wording addresses and what it leaves open, term by term, including the fallback rules for cancellation, delay, missing data and challenged results, where gaps most often sit.