The CFTC issued No-Action Letter 21-11 granting relief from certain swap reporting and recordkeeping requirements for certain binary options transactions traded on DCM KalshiEX LLC and cleared by DCO LedgerX, LLC. In October 2024, the CFTC issued a staff letter modifying CFTC Letter No. 21-11 to cover transactions cleared through Kalshi Klear LLC, a CFTC-registered DCO.
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