2026 Membership Book FINAL

USCA4 Appeal: 25-1892

Doc: 16

Filed: 10/15/2025

Pg: 29 of 97

provides that the CFTC “may”— but need not —“determine” event contracts

to be contrary to the public interest if they “involve”:

(I)

activity that is unlawful under any Federal or State law;

(II) terrorism; (III) assassination; (IV) war; (V) gaming; or (VI) other similar activity determined by the Commission, by rule or regulation, to be contrary to the public interest. Id . § 7a-2(c)(5)(C)(i); see 17 C.F.R. § 40.11. No such contract “determined by

the Commission to be contrary to the public interest ” may be listed. 7 U.S.C.

§ 7a-2(c)(5)(C)(ii). Absent an adverse public-interest determination,

however, an exchange may list event contracts involving the Special Rule’s

enumerated activities, subject to the CFTC’s exclusive jurisdiction. E. Congress Sets Forth A Comprehensive Scheme For Regulating Derivatives Trading. The CEA today sets out a “comprehensive regulatory structure” for entities seeking to offer derivatives. Curran , 456 U.S. at 356 (quotation

marks omitted). The principal requirement is that entities become

“designated” as contract markets , known as DCMs. DCMs must comply with

myriad federal obligations designed to ensure orderly trading and prevent “price manipulation, cornering and other market disturbances.” Am. Agric. ,

977 F.2d at 1151.

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