Last month Turnkey Trading Partners (Turnkey) wrote about the reemergence of event contracts. This article traced a path from specialized, low-profile products under Commodity Futures Trading Commission (CFTC) oversight to the center of a rapidly evolving legal and regulatory storm. Platforms like Kalshi and Robinhood pushed these contracts into the spotlight by offering markets on everything from election outcomes to Super Bowl results. Now these firms, and others like them, are facing a growing list of lawsuits from state gaming commissions, challenges from tribal governments, and increasing federal scrutiny. Turnkey is observing a flurry of CFTC and National Futures Association (“NFA”) registration applications coming through our doors. Event contracts are the new gold rush for 2025.

FanDuel–CME Partnership Raises the Stakes

During August of 2025, FanDuel and Chicago Mercantile Exchange Group (CME) announced a partnership.  This announcement adds yet another layer to this turmoil. It signals that event contracts are moving beyond “specialized” status toward mainstream financial products. Some of the biggest players in both derivatives and sports betting are now aligned. But the timing of this announcement raises key questions. Are event contracts legitimate financial instruments or disguised gambling wagers? Who decides where federal commodities oversight ends and state gaming laws begin? And will the arrival of large, well-capitalized players like CME and Fan Duel raise the regulatory bar for everyone else? So far, the industry response has been to register first and ask questions later.

How Firms Are Approaching Registration

Turnkey has watched this shift firsthand through its work with Futures Commission Merchants (FCMs), Commodity Trading Advisors (CTAs), Introducing Brokers (IBs), and various event contract exchange operators. Almost daily Turnkey is contacted by groups exploring registration for event-driven and binary options products. Rumor has it that the line of people who have applied for Designated Contract Market (DCM) status is so long many applications won’t be touched for months, let alone approved due to CFTC back log. NFA has also been rumored to be “slow walking” FCM and/or IB registrations which should offer a faster, less costly alternative. Each track carries distinct regulatory requirements, capital obligations, and supervisory expectations. Firms are carefully weighing which approach best aligns with their business model, risk appetite, and budget. One thing however is consistent, both the gaming industry and the financial services industry are vying for control of a multi-billion dollar industry and speed is of the essence.

Comparing Registration Paths Under CFTC Oversight

DCM status offers the broadest authority, essentially registering as a full exchange with control over listing, trading, and clearing. DCM applicants must demonstrate the ability to meet rigorous Core Principles under the Commodity Exchange Act (CEA), including robust market surveillance, financial resource requirements, and customer protection measures.

An FCM registration allows a firm to solicit and accept orders for futures and options, handle customer funds, and route trades to a DCM for execution. This path often suits firms that want to distribute event contracts without directly operating an exchange, but FCMs must also meet strict financial requirements, maintain customer segregation of funds, and implement detailed risk management programs, all of which can be costly and complex for new entrants.

For firms that want a lighter operational footprint, IB registration offers the ability to introduce customer accounts to an FCM without handling customer funds directly. This structure can be attractive for technology platforms or marketing-focused businesses seeking to participate in event-driven markets without taking on the full compliance burden of an FCM or DCM.

Many industry participants are currently operating offshore form the United States. Others have built novel technology solutions which will serve as modern trade execution platforms. Additionally, existing CFTC registrants are all looking for angles to get in on the action. Regardless of the solution, a well thought out strategy is a most to ensure a path to success is possible.

Turnkey’s Perspective on Moving Forward

Litigation risk remains the single greatest concern for new applications in the event-contracts space. While federal registration through the CFTC is a prerequisite, it offers no protection against state-level enforcement actions. It also does not guarantee that tribal or other groups may not pursue other available legal recourse.  The current patchwork nature of financial services and gaming rules and regulations within the United States means firms must anticipate legal challenges when entering this nascent market. Until courts clarify the boundary between federal commodities regulation and state or tribal gambling oversight, firms face a difficult choice: proceed with registration amid uncertainty or wait for clearer legal guidance sacrificing speed to market.

Ultimately, success will depend less on the registration path itself and more on proactive strategy. Firms that engage regulators early, implement robust compliance programs, and manage risk meticulously will be best positioned to navigate the uncertainty—and capitalize on the opportunities—as this market evolves. The 1850’s gold rush saw many winners and losers. Event contract regulation will produce similar results. For both the gaming and financial services industry the stakes perhaps have never been higher.

To understand how to navigate the regulatory challenges and capitalize on the opportunities in event contracts, schedule a consultation with a Turnkey compliance expert today. Turnkey is at the forefront of CFTC and NFA regulation. Our experience and knowledge of industry rules, regulations, and best practices can be an invaluable tool for those looking to enter the binary options and event contract market space.