Submission Pursuant to Commission Regulation 40.2(a)

Rothera Exchange and Clearing LLC · received by the CFTC 23 October 2026 · the filing (PDF)

Summary

Warrant Check read 9 operative provisions in this filing. Across them, 19 of 54 checks are present, 8 partial and 27 absent. 2 provisions have 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.

19 present8 partial27 absent

What the wording addresses

Payment Criterion - margin >6 points — every check present.
“Kentucky Wildcats win by more than 6 points”
Suspended game resumption: Independent Verification, Suitable Method, Defined Benchmark, Conclusive Link, Comprehensive Coverage.
“shall settle based on the final result ... as so resumed”
Disqualification/Vacated result: Comprehensive Coverage, Relevant Timeline.
“the market will resolve to "No" for the Kentucky Wildcats”
Retracted/corrected result reliance — every check present.
“rely on the final corrected result published by the Source Agency”

What the wording leaves open

Source Agency hierarchy / clearly erroneous override “Exchange, in its sole discretion, determines such result”
- Independent Verification — Absent: rests on the Exchange's own sole discretion, not externally verifiable evidence
- Suitable Method — Absent: no procedure described for how 'clearly erroneous' is assessed
- Defined Benchmark — Absent: no standard defines what makes a result 'clearly erroneous'
- Conclusive Link — Absent: no named standard - entailment cannot be assessed
- Comprehensive Coverage — Absent: no defined evidentiary procedure exists to assess coverage
- Relevant Timeline — Absent: only bound is 'prior to Expiration'; no evidentiary timeframe for the discretionary review itself
What would close it: Define objective criteria and a verification process for determining a result is clearly erroneous before overriding the hierarchy.
Abandoned/Cancelled/Not Scheduled contingency “resolve based on the last fair market price as determined”
- Independent Verification — Absent: fair market price 'as determined by the Exchange' is the Exchange's own determination; no named methodology supplied
- Suitable Method — Absent: no procedure given for computing FMP at the certainty needed to substitute for the game outcome
- Defined Benchmark — Absent: no standard for FMP computation is stated; only a reference to DCM Rule 7.2
- Conclusive Link — Absent: no named standard - entailment cannot be assessed
- Comprehensive Coverage — Partial: presumably limited to this Contract's market but FMP computation scope undefined
- Relevant Timeline — Partial: timing of the FMP snapshot relative to the obligation period is not specified
- Relies on material referred to but not in the public filing.
What would close it: Include the text of DCM Rule 7.2 specifying the objective method for determining fair market price.
Suspended game resumption “shall settle based on the final result ... as so resumed”
- Relevant Timeline — Partial: no named source confirms the game is 'officially scheduled to resume'; relies on unspecified league announcement
What would close it: Specify which Source Agency or official announcement establishes that the game is officially resuming from suspension.
Forfeit provision “the market ... will resolve based on the determination of the final score”
- Independent Verification — Absent: no source or process named for determining a 'final score' where no game was played
- Suitable Method — Absent: method cannot establish a score for a game that never occurred
- Defined Benchmark — Absent: no forfeit-scoring convention or standard is named
- Conclusive Link — Absent: no named standard - entailment cannot be assessed
- Comprehensive Coverage — Absent: unclear what the 'final score' evidence would even cover absent a played game
- Relevant Timeline — Absent: no time period defined since no game occurs
What would close it: Specify a defined forfeit scoring convention per governing league rules and the Source Agency confirming forfeiture.
Disqualification/Vacated result “the market will resolve to "No" for the Kentucky Wildcats”
- Independent Verification — Partial: presumably confirmed by NCAA/league ruling, but no specific confirming source or document is named
- Suitable Method — Partial: a league ruling could establish the fact but is not tied to the defined Source Agency hierarchy
- Defined Benchmark — Partial: the triggering conditions are named but no confirming documentation standard is specified
- Conclusive Link — Partial: if genuinely confirmed, resolving 'No' follows, but confirmation source is undefined
What would close it: Name the authoritative source (e.g., NCAA official ruling) and documentation required to confirm disqualification/vacatur.
Delayed/Unavailable result “Exchange may wait up to 24 hours ... in its sole discretion”
- Independent Verification — Absent: 'sole discretion' is the Exchange's own judgment, not third-party receivable evidence
- Suitable Method — Absent: no procedure described for how the Exchange determines the outcome absent an official result
- Defined Benchmark — Absent: no standard governs the discretionary resolution
- Conclusive Link — Absent: no named standard - entailment cannot be assessed
- Comprehensive Coverage — Absent: no defined scope for the discretionary process
- Relevant Timeline — Partial: a 24-hour wait period is specified, bounding when discretion may be exercised
What would close it: Define objective fallback criteria or an independent process for resolving the Contract when results are delayed beyond 24 hours.
Contingencies fallback to DCM Rule 7.2 “the Contract shall resolve pursuant to DCM Rule 7.2”
- Independent Verification — Absent: Rule 7.2's evidentiary basis is not supplied; ultimately defers to the Exchange's own process
- Suitable Method — Absent: cannot assess capability since the referenced rule's procedure is absent
- Defined Benchmark — Absent: no standard available in the supplied text
- Conclusive Link — Absent: no named standard - entailment cannot be assessed
- Comprehensive Coverage — Absent: cannot be assessed; underlying rule not provided
- Relevant Timeline — Absent: cannot be assessed; underlying rule not provided
- 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 describing the fallback settlement methodology.

Every provision read

Payment Criterion - margin >6 points

“Kentucky Wildcats win by more than 6 points”

Determination: the official final score shows Kentucky won by more than 6 points · Consequence: Expiration Value set to Yes/No and Settlement Value paid to long or short holders

Present Independent Verification. official final score from named, hierarchical Source Agencies (NCAA.com, ESPN, etc.) - receivable, neutral evidence

Present Suitable Method. a reported final score directly establishes the point margin at the precision asserted

Present Defined Benchmark. explicit threshold of 'more than 6 points' is named

Present Conclusive Link. meeting the >6-point margin in the final score directly establishes the Payment Criterion

Present Comprehensive Coverage. evidence covers exactly the single named game the claim concerns

Present Relevant Timeline. result considered through the Expiration Time on the Expiration Date, matching the obligation period

Source Agency hierarchy / clearly erroneous override

“Exchange, in its sole discretion, determines such result”

Determination: a reported result is 'clearly erroneous', justifying deferral to a different result · Consequence: Exchange may override the Source Agency hierarchy and use a corrected result for settlement

Absent Independent Verification. rests on the Exchange's own sole discretion, not externally verifiable evidence

Absent Suitable Method. no procedure described for how 'clearly erroneous' is assessed

Absent Defined Benchmark. no standard defines what makes a result 'clearly erroneous'

Absent Conclusive Link. no named standard - entailment cannot be assessed

Absent Comprehensive Coverage. no defined evidentiary procedure exists to assess coverage

Absent Relevant Timeline. only bound is 'prior to Expiration'; no evidentiary timeframe for the discretionary review itself

Abandoned/Cancelled/Not Scheduled contingency

“resolve based on the last fair market price as determined”

Determination: the game was abandoned, cancelled, or not (re)scheduled before Expiration Time, warranting fair-market-price settlement · Consequence: holders paid based on fair market price instead of the game outcome

Absent Independent Verification. fair market price 'as determined by the Exchange' is the Exchange's own determination; no named methodology supplied

Absent Suitable Method. no procedure given for computing FMP at the certainty needed to substitute for the game outcome

Absent Defined Benchmark. no standard for FMP computation is stated; only a reference to DCM Rule 7.2

Absent Conclusive Link. no named standard - entailment cannot be assessed

Partial Comprehensive Coverage. presumably limited to this Contract's market but FMP computation scope undefined

Partial Relevant Timeline. timing of the FMP snapshot relative to the obligation period is not specified

Suspended game resumption

“shall settle based on the final result ... as so resumed”

Determination: the game officially resumes from the point of suspension before Expiration Time, and the resulting final score · Consequence: Contract settles on that final result rather than via fair-market-price fallback

Present Independent Verification. relies on the same official final-score/Source Agency mechanism as the core Payment Criterion

Present Suitable Method. final score establishes the margin as in the main clause

Present Defined Benchmark. same >6-point threshold applies

Present Conclusive Link. same entailment as the core provision once the game is officially resumed and completed

Present Comprehensive Coverage. same single specified game

Partial Relevant Timeline. no named source confirms the game is 'officially scheduled to resume'; relies on unspecified league announcement

Forfeit provision

“the market ... will resolve based on the determination of the final score”

Determination: Kentucky Wildcats forfeited before the game began, and a 'final score' can be determined for the unplayed game · Consequence: market resolves based on this determined score

Absent Independent Verification. no source or process named for determining a 'final score' where no game was played

Absent Suitable Method. method cannot establish a score for a game that never occurred

Absent Defined Benchmark. no forfeit-scoring convention or standard is named

Absent Conclusive Link. no named standard - entailment cannot be assessed

Absent Comprehensive Coverage. unclear what the 'final score' evidence would even cover absent a played game

Absent Relevant Timeline. no time period defined since no game occurs

Disqualification/Vacated result

“the market will resolve to "No" for the Kentucky Wildcats”

Determination: Kentucky Wildcats were disqualified, deemed ineligible, or had the result vacated after the match started but before Contract expiry · Consequence: Contract automatically resolves to 'No' regardless of the on-field margin

Partial Independent Verification. presumably confirmed by NCAA/league ruling, but no specific confirming source or document is named

Partial Suitable Method. a league ruling could establish the fact but is not tied to the defined Source Agency hierarchy

Partial Defined Benchmark. the triggering conditions are named but no confirming documentation standard is specified

Partial Conclusive Link. if genuinely confirmed, resolving 'No' follows, but confirmation source is undefined

Present Comprehensive Coverage. limited to the Kentucky Wildcats in this specific game

Present Relevant Timeline. window is defined as after match start but before Contract expiry

Delayed/Unavailable result

“Exchange may wait up to 24 hours ... in its sole discretion”

Determination: the official match result remains delayed or unavailable beyond the waiting period, justifying discretionary resolution · Consequence: Exchange resolves the Contract in its sole discretion

Absent Independent Verification. 'sole discretion' is the Exchange's own judgment, not third-party receivable evidence

Absent Suitable Method. no procedure described for how the Exchange determines the outcome absent an official result

Absent Defined Benchmark. no standard governs the discretionary resolution

Absent Conclusive Link. no named standard - entailment cannot be assessed

Absent Comprehensive Coverage. no defined scope for the discretionary process

Partial Relevant Timeline. a 24-hour wait period is specified, bounding when discretion may be exercised

Retracted/corrected result reliance

“rely on the final corrected result published by the Source Agency”

Determination: a Source Agency retracted/corrected a published result, or confirmed it was compromised, and issued a final corrected result before Expiration · Consequence: Exchange uses the corrected result for settlement instead of the original

Present Independent Verification. relies on the Source Agency's own published correction - a named neutral third party

Present Suitable Method. a published correction can establish the corrected final result

Present Defined Benchmark. 'final corrected result published ... prior to the Expiration Time' is the named standard

Present Conclusive Link. a corrected published result establishes the margin for settlement

Present Comprehensive Coverage. tied to the same single game

Present Relevant Timeline. bounded to publication 'prior to the Expiration Time'

Contingencies fallback to DCM Rule 7.2

“the Contract shall resolve pursuant to DCM Rule 7.2”

Determination: no result is confirmed within the extended contingency period · Consequence: Contract resolves pursuant to DCM Rule 7.2's (unseen) mechanism

Absent Independent Verification. Rule 7.2's evidentiary basis is not supplied; ultimately defers to the Exchange's own process

Absent Suitable Method. cannot assess capability since the referenced rule's procedure is absent

Absent Defined Benchmark. no standard available in the supplied text

Absent Conclusive Link. no named standard - entailment cannot be assessed

Absent Comprehensive Coverage. cannot be assessed; underlying rule not provided

Absent Relevant Timeline. cannot be assessed; underlying rule not provided

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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