Rule citations are to the proposal as published at 91 FR 50926 on August 6, 2026 (RIN 3038-AF76); registration and corporate facts are stated as of August 9, 2026. This describes a proposal — every requirement discussed is subject to change through a comment process that closes October 5, 2026. Three points are attributed rather than asserted: the four market-maker exception conditions and the 35% board-independence figure are as characterized by Davis Polk from the proposed rule text, because the Federal Register HTML truncates the operative provisions; the Kalshi Trading board overlap is Sportico’s reporting, not a CFTC finding; and the preamble’s count of roughly eight DCMs with affiliated market makers is not itemized, so “none disclosed” in the venue table means no public disclosure was found, not that none exists. The collision-severity matrix is an analytical judgment, not a legal opinion, and characterizations of how any venue is likely to comment are our inference — no comment letters existed at the time of writing. Nothing here is legal advice or a compliance opinion on any registrant. Research and education, not investment advice.