Will England win the first Twenty20 International between England and New Zealand on September 7, 2027?
Railbird Exchange, LLC · received by the CFTC 21 October 2026 · the filing (PDF)
Warrant Check read 10 operative provisions in this filing. Across them, 38 of 60 checks are present, 11 partial and 9 absent. 4 provisions have every check present.
38 present11 partial9 absent2 not assessedThe payout rule here is “Payout Criterion / Official Result determination”: the rule that says what makes the contract pay Yes or No. The other 9 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 9 addressed |
| Settlement method described | Addressed | 4 of 9 addressed |
| Covers every case it applies to | Addressed | 7 of 9 addressed |
| Timing set | Addressed | 7 of 9 addressed |
| Terms in the public filing | In the filing | 8 of 9 in the filing |
What the wording addresses
- Payout Criterion / Official Result determination — every check present.
“resolves YES if [entity] is declared the winner of [event]” - Match Abandoned - 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, Conclusive Link, Comprehensive Coverage, Relevant Timeline.
“each team's Contract resolves at $0.50” - Source Agency 48-hour non-report referral: Independent Verification, Suitable Method, Defined Benchmark, Comprehensive Coverage, Relevant Timeline.
“does not report the relevant result within 48 hours of the Conclusion” - Mutually Exclusive Set Aggregate Payout — every check present.
“aggregate payout across all Contracts in a Mutually Exclusive Set shall equal” - Position Accountability Reporting — every check present.
“holds or controls aggregate positions at or above the applicable accountability level” - Incorrect Listed Schedule — every check present.
“settles based on the actual [event] as scheduled by the governing body” - Unconditionally Determined Early Settlement: Comprehensive Coverage, Relevant Timeline.
“if the outcome of a Contract is Unconditionally Determined at any point”
What the wording leaves open
- Match Abandoned - 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 'last fair market price' value itself rests on Exchange determination with no named methodology or data source.
- Suitable Method — Partial: Procedure can establish that no official result was issued, but cannot by itself establish a specific, verifiable settlement price.
- Defined Benchmark — Partial: 'Last fair market price as determined by the Exchange' is named but undefined (no formula, time window, or data source).
- Conclusive Link — Partial: Because the standard is loosely defined, satisfying it does not reliably establish a specific, verifiable settlement value.
- Tie - No Winner Determined “each team's Contract resolves at $0.50”
- Defined Benchmark — Partial: 'No winner determined under official playing conditions' is named but what counts if a tiebreaker is itself interrupted is not detailed.
- Source Agency 48-hour non-report referral “does not report the relevant result within 48 hours of the Conclusion”
- Conclusive Link — Partial: Meeting the 48-hour non-report condition triggers referral, but the ultimate resolution to last fair market price is only discretionary ('may'), weakening entailment of the full consequence.
- Clearly Erroneous Result Referral “the Exchange determines that a reported result is clearly erroneous”
- Independent Verification — Absent: Rests entirely on the Exchange's own subjective determination; no named objective evidence or third-party check.
- Suitable Method — Absent: No procedure is specified for establishing error beyond the Exchange's own judgment.
- Defined Benchmark — Absent: 'Clearly erroneous' is undefined - no threshold or criteria given.
- Comprehensive Coverage — Partial: Presumably limited to the reported result of this match, but not explicitly scoped.
- Relevant Timeline — Partial: Timing of this determination (e.g., relative to Expiration) is not specified.
- Unconditionally Determined Early Settlement “if the outcome of a Contract is Unconditionally Determined at any point”
- Independent Verification — Absent: No named evidence source or determining party/procedure is given for reaching an 'Unconditionally Determined' conclusion.
- Suitable Method — Absent: A definition is supplied but no operational procedure is specified capable of establishing certainty at the asserted strength.
- Defined Benchmark — Partial: A conceptual definition ('certainty regardless of further activity') is given but functions as a concept, not an operational threshold or test.
- Conclusive Link — Partial: If the definition could be objectively verified it would establish the claim, but no verification method is specified.
- Market Outcome Review for Undetermined Expiration Value “the Exchange may determine payouts pursuant to Rule 7.1”
- Independent Verification — Absent: The operative procedure (Rule 7.1) is referenced but its content is not included in the supplied text.
- Suitable Method — Absent: Cannot assess whether the referenced procedure can establish the claim, since its content is not supplied.
- Defined Benchmark — Absent: No standard is given in the supplied text; it is deferred entirely to Rule 7.1, not provided.
- Comprehensive Coverage — Absent: Coverage of the review process (which positions/outcomes it reaches) is not specified in the supplied text.
- Relevant Timeline — Partial: Triggered 'on the Expiration Date' but the duration/timing of the review procedure itself is not specified here.
- Relies on material referred to but not in the public filing.
Every provision read
Payout Criterion / Official Result determination
“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 (pays long positions) or NO (pays short positions)
Match Abandoned - No Official Result
“resolves to the last fair market price, as determined by the Exchange”
Determination: the match started and was abandoned with no official result 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: the match concluded in a tie and no winner was determined under official playing conditions · Consequence: each team's Contract resolves at $0.50
Source Agency 48-hour non-report referral
“does not report the relevant result within 48 hours of the Conclusion”
Determination: the Source Agency does not report the relevant result within 48 hours of the Conclusion of [event] · Consequence: Contract is referred to the Market Outcome Review Process and may resolve to the last fair market price
Clearly Erroneous Result Referral
“the Exchange determines that a reported result is clearly erroneous”
Determination: a reported result is 'clearly erroneous' as determined by the Exchange · Consequence: the matter is referred to the Market Outcome Review Process
Mutually Exclusive Set Aggregate Payout
“aggregate payout across all Contracts in a Mutually Exclusive Set shall equal”
Determination: the individual Contracts within a Mutually Exclusive Set have resolved per their own settlement provisions · Consequence: remaining Contracts' resolve so that aggregate payout across the Set equals the Contract Size
Position Accountability Reporting
“holds or controls aggregate positions at or above the applicable accountability level”
Determination: a Member holds or controls aggregate positions at or above the 125,000-contract accountability level · Consequence: Member must, upon request, provide position/strategy/hedging information and consents to Exchange trading restriction
Incorrect Listed Schedule
“settles based on the actual [event] as scheduled by the governing body”
Determination: the start date/time displayed by a third party for [event] was incorrect · Consequence: Contract settles based on the actual event as scheduled by the governing body, unaffected by the display error
Unconditionally Determined Early Settlement
“if the outcome of a Contract is Unconditionally Determined at any point”
Determination: the outcome of the Contract is Unconditionally Determined (certain regardless of further competition activity) · Consequence: Contract settles based on that determination regardless of any subsequent event
Market Outcome Review for Undetermined Expiration Value
“the Exchange may determine payouts pursuant to Rule 7.1”
Determination: the Expiration Value cannot be determined on the Expiration Date · Consequence: the Exchange may determine payouts pursuant to Rule 7.1
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.