2026 Membership Book FINAL

USCA4 Appeal: 25-1892

Doc: 16

Filed: 10/15/2025

Pg: 42 of 97

jurisdiction … withdraws any concurrent jurisdiction ”). The CFTC’s

exclusive jurisdiction over trading on DCMs is no different.

Other features of Section 2(a) ’s text underscore its preemptive effect.

Section 2(a) contains a savings clause preserving the jurisdiction of “other

regulatory authorities” under the laws “of any State.” 7 U.S.C. § 2(a)(1)(A). C rucially, the clause applies “ [e]xcept as hereinabove provided ” by the grant of exclusive jurisdiction to the CFTC. Id . (emphasis added). That language enables a “logical inference” of preemption as to matters within the CFTC’s jurisdiction. See Omnipoint Commc ’ ns, Inc. v. City of Huntington Beach , 738 F.3d 192, 195-196 (9th Cir. 2013) (interpreting savings clause with an “ [e]xcept as provided ” proviso). Congress added the proviso specifically to

ensure that “the Commission’s jurisdiction, where applicable , supersedes

State as well as Federal agencies.” S. Rep. No. 93-1131, at 6.

2. The backdrop against which Congress regulated in 1974 confirms its

preemptive intent. When Congress considered the 1974 amendments, the

CEA did not “impair any State law applicable to any transaction” regulated

by the statute. 7 U.S.C. § 6c (1936). The Supreme Court had explained that without this proviso, the CEA would “ almost certainly conflict with state laws,” but that this proviso “serve[d] the function of preventing supersedure and preserving state control.” Rice v. Bd. of Trade of Chi. , 331 U.S. 247, 255

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