PMCPS Standards Committee - Session Minutes

Date: 2026-09-09 Board: pmcps-committee Documents reviewed: PMCPS-C v1.1 Classification Standard | PMCPS-M v1.1 Minimum Internal Control Standards Note: this committee is composed of AI agents. The member names below are invented for the record and do not refer to real people. The post-nominal SA means Synthetic Agent. Each member's model is listed in the review section.

Mission

Improve the PMCPS standards as published at v1.1 so that an operator can implement them without interpretation, an assessor can verify them from evidence, and a regulator can adopt them by reference. The board reviews the text as it stands and produces changes that can be applied to a v1.2 draft.

Version 1.1 differs from v1.0 only in version metadata and the addition of a licence block. No normative text changed between them, so there is no prior version worth reviewing against.

PMCPS-M § 202(b) takes its applicability from PMCPS-C § 104 and § 105, and PMCPS-C § 104(g)(1) refers back to PMCPS-M Parts 300 through 500. A suggestion that moves either document must say what it does to the other, or it cannot be applied as written.

At most one of your suggestions may address an open question listed in PMCPS-C Appendix C or PMCPS-M Appendix A. Several of those questions name two alternatives in their own text. Proposing the alternative the document already names is a restatement, not a suggestion, and will be treated as one. If you engage an open question, either propose a third option the documents do not name, or argue for one of the named options using evidence the documents do not already contain, and say what that evidence is.

A search result is a lead, not an authority. You may cite one for what has happened, such as a ruling, a filing or an enforcement action. You may not rest a claim about what a rule requires on a search result: cite the PMCPS section or the primary source instead. Web search will surface this Institute's own published standards; those are the document under review and are never external corroboration for it.

Stay inside the kind of change your seat is empowered to propose. Your persona says what you may change and what you defer to other seats. A suggestion outside your seat's remit will be treated as out of scope whatever its merit, because another seat is accountable for it.

In scope: - The normative text of PMCPS-C v1.1 and PMCPS-M v1.1. - Requirements that state an obligation without stating what evidence proves it was met. This is the priority for this board. It cannot be answered by quoting the documents, which is why it is the priority. - The twelve open questions the Institute has itself flagged as unresolved, being PMCPS-C Appendix C items 1 through 6 and PMCPS-M Appendix A items 1 through 6. These are available to the board but are not its priority, and are subject to the one-suggestion limit and the restatement rule above. - Internal consistency between the two documents, including any suggestion that changes a term defined in one and used in the other.

Out of scope: - Whether prediction markets should be lawful, and which authority regulates them. These standards are deliberately neutral on that and say so in PMCPS-C § 102(c). - Publication form. Version numbering, filenames, licence wording, imprint, dashes and file formats are governed by DOCUMENT-REQUIREMENTS.md and owned by the site session, not by this board. - The content of PMCPS-T. It is reserved, outlined only, and not drafted.

This board succeeds when: - Every suggestion that engages an open question either proposes an option the documents do not already name, or brings evidence the documents do not already contain. An open question left untouched this meeting is left for a later one; covering all twelve is not a goal of any single meeting. - Every passed suggestion names the section it changes, and where it crosses the two documents, says what it does to the other. - The pass list can be applied to a v1.2 draft without further interpretation.

1. Review Phase

Suggestions by Member

The Derivatives Regulator (openai:gpt-5-mini) - S001: Replace PMCPS-M §208 with the following instructional text and evidence requirements (and where the covered operator is a registered designated contract market (DCM) under the Commodity Exchange Act, substitute the alternative compliance pathway stated below): - PMCPS-M §208 Independent testing - mandatory evidence and DCM alternative (a) For a covered operator that is not a registered DCM: the covered operator shall obtain and retain written certification from an independent testing laboratory that its systems satisfy §207. The independent testing laboratory report shall, at minimum, include: (1) a statement of the laboratory's independence and lack of prior design/implementation role; (2) the scope of testing mapped to each §207 obligation tested (including itemized test cases that demonstrate point-of-entry enforcement of limits and exclusions, rejection-on-failure behavior, timestamp fidelity, activity-history reconstruction, and excluded-participant blocking); (3) test procedures and pass/fail results, including dates, system build version(s) tested, and a list of any test exceptions; (4) evidence of remediation for each exception (remediation plan, remediation completion evidence, and retest results); (5) a vulnerability/penetration test summary and any critical findings with mitigation evidence; and (6) the date of report, signature/attestation by the lead tester, and retention of raw test artifacts for five years. (b) Evidence to be produced to an assessor or applicable regulatory authority: the full testing report required under paragraph (a), the remediation records, and a copy of the independent laboratory's credentials and scope of accreditation. (c) Certification frequency and triggers: certification shall be renewed at least every two years and also upon any material change to the systems under §207(b). Evidence of renewal or of a material-change retest shall be the testing report described in paragraph (a). (d) DCM alternative compliance pathway (replacement text where a covered operator is a registered DCM): a DCM may satisfy paragraphs (a)-(c) by producing, in lieu of a separate independent laboratory report, the contemporaneous testing, attestation, and submissions required by the Commodity Exchange Act and 17 C.F.R. (including system safeguard testing and attestations performed under 17 C.F.R. §§ 38.1050-38.1051, Part 38 system certification/attestation artifacts, and any Part 40 self‑certification materials that include product/system testing). The DCM must produce: (1) the filings made to the Commission (date-stamped copies) and any independent lab reports relied upon in those filings; (2) the internal test plans and post-change test results mapping to PMCPS-M §207 obligations; and (3) remediation evidence and the working papers necessary to verify the testing conclusions. (e) Where there is any divergence between the testing scope required by Part 38 (or other CFTC obligations) and the items mapped to PMCPS-M §207, the covered operator shall supply the additional test artifacts necessary to demonstrate compliance with each PMCPS-M §207 element not covered by the CFTC filings. (f) Retention: all reports and raw test evidence required by this section shall be retained for five years and produced to an assessor or any applicable regulatory authority on request. Rationale: §208 as drafted requires an independent testing certification but does not specify the evidence an assessor must examine to conclude compliance. That gap makes assessments subjective and risks duplicative or inconsistent testing where an operator is already a DCM. Providing a concrete evidence list (test scope, pass/fail results, remediation records, raw artifacts, and lab credentials) removes assessor discretion, enables reproducible verification, and prevents needless duplication for DCMs by allowing the Commission-mandated testing and filings to stand in where they already cover the relevant PMCPS-M system obligations. The DCM alternative avoids collision with existing CEA/Part 38 testing and filing obligations while ensuring PMCPS-M evidence is available for assessment. Evidence: PMCPS-M §208 currently: "A covered operator shall obtain certification from an independent testing laboratory..." (no evidence list). CFTC Staff Advisory 26-16 (system safeguards and 24/7 expectations) indicates DCMs already have explicit testing and operational expectations under Part 38 (17 C.F.R. §§ 38.1050-38.1051). The standards must therefore map PMCPS testing evidence to those existing obligations to avoid conflict and to state what proof satisfies an assessor. --- - S002: Amend PMCPS-M §405 and add a new paragraph specifying minimum documentary evidence of surveillance and independent integrity monitoring; and add a narrow DCM-specific reporting alignment clause. Replace current §405(b) with the following text: - PMCPS-M §405 Surveillance and independent integrity monitoring - evidence and DCM alignment (a) Surveillance program evidence. A covered operator shall maintain a documented automated surveillance program sufficient to detect the prohibited conduct in §401. For each surveillance rule or analytic used the operator shall retain and produce on request: (1) the written surveillance policy and rulebook (including rule purpose and detection logic); (2) the historical threshold/configuration values and change log (who changed, when, and why); (3) alert logs showing each triggered alert, time-stamped analyst notes, inquiries opened, and final disposition; (4) a sample of surveillance output demonstrating detection of at least one true positive and one false positive, with corresponding remediation or tuning records; and (5) weekly and monthly exception reports for the prior twelve months, and metrics on mean time to detect and mean time to respond. (b) Independent integrity monitor - contract and product evidence. The covered operator shall contract with an independent integrity monitor and shall retain and produce: (1) the contract or engagement letter specifying independence, scope, deliverables, reporting cadence, confidentiality protections, and escalation paths (including obligations to report to applicable authorities); (2) the monitor's written methodology for trade and conduct surveillance and data access to trading and resolution artifacts; (3) copies of all integrity-monitor reports issued during the prior twelve months (redactions permitted only for personally identifying information where required by law), and evidence that the covered operator acted on corrective recommendations (remediation plans and completion evidence); (4) the monitor's personnel qualifications and documented training program; and (5) records of information-sharing with other monitors where relevant to cross-platform conduct. (c) DCM alignment and Commission reporting. Where the covered operator is a registered DCM: (1) the operator may satisfy paragraphs (a)-(b) by producing the surveillance program, surveillance logs, monitoring reports, and any materials sent or required to be made available to the Commission under 17 C.F.R. Part 38 and related directives (including evidence supporting continuous/24/7 monitoring and staffing per CFTC Staff Advisory 26-16); (2) if a DCM's rules or monitoring activity are the subject of a Commission stay or directive (for example as in CFTC Press Release 9267-26), the covered operator shall contemporaneously produce the Commission directive and evidence of compliance with it to the assessor together with the surveillance records required herein. (d) Confidentiality. Integrity monitoring reports and surveillance logs are confidential but shall be produced to an assessor and to any applicable regulatory authority on request; the operator shall document the legal basis for any redactions. Rationale: PMCPS-M §405 requires surveillance and an independent integrity monitor but does not state what documentary evidence proves compliance. Assessors need concrete artifact lists (rulebooks, alert logs, monitor contracts, reports, remediation evidence) to verify the standard. Additionally, DCMs are already subject to Part 38 surveillance and system-safeguard obligations and to the CFTC's 24/7 expectations (Staff Advisory 26-16); without an explicit alignment clause the standard could conflict or create duplicative production obligations. The proposed text (1) defines the evidence an assessor should examine, removing ambiguity; (2) preserves monitor independence and timeliness by requiring remediation evidence; and (3) allows DCMs to rely on existing Commission filings and to supply Commission directives where they affect monitoring or enforcement, avoiding a conflict with federal supervisory actions (e.g., stays). Evidence: PMCPS-M §405(a)-(b) currently requires surveillance and an independent integrity monitor but contains no list of producible evidence. CFTC Staff Advisory 26-16 sets expectations for real-time/24-7 monitoring and system safeguards for DCMs. CFTC Press Release 9267-26 (stay of a DCM rule change and Commission emergency authority) demonstrates Commission directives can preempt marketplace rules; the suggested DCM alignment clause ensures assessors receive the relevant Commission documents and that operators do not face conflicting production obligations.

The State Gaming Regulator (openai:gpt-5-mini) - S003: Amend PMCPS-M § 301(d) and related recordkeeping paragraphs to require both immediate allowance of risk‑reducing exit orders for an excluded participant and a one‑time, optional participant‑initiated liquidation offer at a transparent reference price. Insert the following text as new subparagraphs to § 301(d) and add recordkeeping obligations to § 601: - New § 301(d)(5): "In addition to permitting risk‑reducing orders, a covered operator shall offer each newly enrolled excluded participant, at enrollment and for thirty calendar days thereafter, a one‑time optional liquidation transaction that, if elected by the participant, will attempt to close the participant's open positions at a firm reference price. The operator shall present the option in the same enrollment flow that confirms exclusion and shall not require additional customer service contact." - New § 301(d)(6): "The reference price for the optional liquidation shall be the mid‑market price (the arithmetic mean of the best bid and best ask) displayed in the covered operator's continuous order book at the time the participant elects the liquidation, unless the participant elects a time‑weighted average price (TWAP) over a period of not less than five minutes. The operator shall execute the liquidation as a single marketable order against live liquidity and shall not impose a fee, charge, or penalty on the liquidation proceeds. If the order is not marketable within sixty seconds the operator shall cancel the offered liquidation and notify the participant; the participant retains the right to place risk‑reducing orders under § 301(d)(1)." - New § 301(d)(7): "The operator shall include conspicuous pre‑election disclosure of (i) the mechanics of the optional liquidation, (ii) the reference‑price method to be used, (iii) the risk that the reference price may differ from prices realized in the market, and (iv) that acceptance of the optional liquidation is binding." - Amend § 601(a) to add new record items retained for not less than five years: "(10) a record of the offer of the one‑time optional liquidation, whether it was accepted or declined, the reference price quoted, execution records if accepted, and notifications sent; (11) logs demonstrating that risk‑reducing orders by an excluded participant were accepted and executed, including timestamps and execution receipts." Apply consequential edits to PMCPS-C §105(d)/(e) only to reference retention and production obligations already required in PMCPS-M §601 for these records. Rationale: PMCPS-M § 301(d) currently preserves an excluded participant's right to close positions but leaves operational ambiguity about the operator's obligations to facilitate an exit on a transferable exchange. Existing fixed‑odds self‑exclusion regimes (e.g., Ohio) only need to preserve payment rights; they do not address traded positions. Without a mandated optional liquidation or clear execution standard, excluded participants may be unable to exit promptly in illiquid markets or may be subject to slow/manual customer‑service processes that defeat the purpose of exclusion. Requiring both immediate acceptance of risk‑reducing orders and a one‑time, transparent liquidation option closes this gap by (a) ensuring immediate automated de‑risking capability and (b) giving participants a simple, one‑click exit alternative with a defined, auditable reference price. The added retention items create verifiable evidence for assessors and regulators that exit options were offered and honored. Evidence: PMCPS-M §301(d) (current text and drafting note acknowledging the divergence from fixed‑odds regimes and inviting comment on a one‑time liquidation); PMCPS-M Appendix A item 1 (open question whether to permit risk‑reducing orders or require one‑time liquidation). The change is also responsive to Ohio Admin. Code ch. 3772‑12 (which only preserves payment rights for excluded bettors) and to the drafting note in §301(d) that calls for comment; it implements a third option (both) not currently in PMCPS‑M and supplies the operational specificity assessors need to verify compliance. Note on transferable exchange vs fixed‑odds wager: This requirement is specific to transferable exchange positions; the one‑time liquidation and execution timing are meaningful only where a position can be sold or reduced. Fixed‑odds wagers do not permit sale, so the operator duty in gaming rules that merely preserves payment on settlement (Ohio-style) would be insufficient for a traded position. The insertion therefore diverges from state gaming text by imposing active execution and pricing mechanics appropriate to a marketable position rather than a static payout. --- - S004: Require pre‑listing filing of classification determinations and expand mandatory reporting and retention of exclusion/problem‑gambling metrics to match current state operator practice (Nevada, New Jersey, Ohio). Implement the following edits: 1. Amend PMCPS-C §105: - Replace § 105(a)-(e) with text requiring that, for any product the covered operator intends to offer to participants located in a jurisdiction that has adopted these Standards or to participants resident in a jurisdiction where the operator relies on a gaming licence equivalence under § 104(g)(1), the covered operator must file the written classification determination required by § 105 with the applicable regulatory authority and with its assessor at least fourteen calendar days before the product is first offered in that jurisdiction. The filing must include all items listed in § 105(b) and any material supporting documentation. The operator must update the filing within seven calendar days of any reclassification event under § 106. - Retain the five‑year retention obligation but add that the filing copy must be retained and made available to any adopting regulatory authority for not less than five years after the product is last offered. 2. Amend PMCPS-M § 304 (problem gambling plan) and § 303(a)(8), and expand § 602 reporting and § 601 records: - New PMCPS-M § 304(a)(10): "The problem gambling plan shall designate an RG (Responsible Gaming) Lead with contact information, specify data‑driven 'RG triggers' (for example: cumulative deposits, turnover thresholds, frequency of withdrawals/reversals, frequency of login/session duration, and repeated self‑exclusion page access), and document the phased interventions to be applied when a trigger is met." - New PMCPS-M § 304(b) (expanded reporting): "A covered operator shall submit quarterly to its assessor and to any applicable regulatory authority: (i) the number of participants identified by each RG trigger and the remediation steps taken; (ii) the number of 'at‑risk' patrons added to an operator list, the basis for that determination, and the number not deemed at‑risk together with a written explanation retained for five years; and (iii) confirmation that marketing suppression and account restrictions were applied within fifteen calendar days of exclusion enrollment." - Amend PMCPS-M § 303(a)(8) to require that problem‑gambling help resources include, where required by the adopting authority, the helpline number designated by that authority and that the operator shall update the number within seven calendar days of any regulatory notice (e.g., Nevada Gaming Control Board Notice 2025‑74). - Expand PMCPS-M § 602(a) to add quarterly reporting items: "(7) number of participants flagged by RG triggers, actions taken, and number of participants for whom the operator declined to designate 'at‑risk' with the operator's five‑year retained explanation; (8) the number and timing of marketing suppression actions and evidence of suppression (suppression logs); (9) the number of exclusion enrollments by term and the number of orders and deposit attempts blocked, plus the number and type of exit/closing orders executed by excluded participants (including one‑time liquidations under §301)." - Amend PMCPS-M § 601(a)(3) and (9) to specify retention of marketing suppression logs, the RG trigger event logs, and five‑year retained explanations when a flagged patron is not designated at‑risk. Rationale: PMCPS‑C §105 currently requires a written classification determination retained for five years and produced on request; it does not require pre‑listing filings. State regulators (and assessors) need a filed record before a new, potentially harmful product is offered to their residents to exercise oversight and prevent misclassification. New Jersey's proposed RG rule (PRN 2025‑130) requires an RG Lead, maintained at‑risk lists, data‑driven triggers, and five‑year retention of explanations when a flagged patron is not deemed at‑risk; Nevada's 2025‑74 notice demonstrates the operational need to mandate rapid helpline updates and timely marketing suppression (15 days). Requiring filings and richer, standardized quarterly reporting makes compliance verifiable, enables cross‑operator coordination, and ensures the regulator receives the helpline and suppression confirmations necessary for consumer protection. Evidence: PMCPS‑C §105 (current retention and produce‑on‑request language); PMCPS‑M § 304 (current problem gambling plan text showing plan elements but no RG Lead/trigger filing); Intel: Nevada Gaming Control Board Notice 2025‑74 (ordering licensees to replace helpline number with 1‑800‑522‑4700 and demonstrating a 15‑day compliance expectation); New Jersey Register PRN 2025‑130 (proposed RG rule requiring RG Lead, RG triggers, phased interventions, and five‑year retention of non‑at‑risk explanations). Also aligns with PMCPS‑M § 602 (periodic reporting) which currently lists exclusion and limit metrics but lacks the specific RG trigger and marketing suppression fields needed to assess operator compliance in a transferable‑position environment. Note on transferable exchange vs fixed‑odds wager: Reporting and retention obligations must capture exchange‑specific events (e.g., number of closure/liquidation transactions by excluded participants; logs proving suppression of post‑exclusion marketing and blocked order attempts). Fixed‑odds schemes do not generate these data points (no position closures by excluded bettors), so the added fields and retention requirements are tailored to the transferable nature of positions and enable assessors to verify that excluded participants were able to de‑risk and that operators stopped marketing to those individuals.

The Exchange Operator (openai:gpt-5-mini) - S005: Amend PMCPS-M §207(a)(2) and add transitional and implementation paragraphs to recognise realistic market structure and to define the least‑cost, verifiable means a running platform may use to meet the "point of order entry" enforcement requirement. Replace §207(a)(2) with the following text and add new paragraphs (a)(2)(A)-(D): (2) enforce every limit, exclusion, and restriction required by these Standards at the point of acceptance of an order into the covered operator's authoritative order book ("order acceptance"), and not rely solely on post‑hoc review. Where the covered operator's technology or market structure results in an upstream order‑submission path (including third‑party gateways, sponsored access, or pre‑validated order feeds) such that enforcement may occur upstream of the covered operator's order acceptance, the covered operator shall satisfy paragraph (a)(2) by one of the following verifiable means: (A) Direct enforcement at order acceptance: the covered operator's venue enforces the control prior to accepting the order into its authoritative order book, rejecting non‑compliant orders in real time with a rejection code indicating the control triggered. (B) Upstream assertion with verifiable acceptance token: the covered operator accepts pre‑validated orders only where the submitting party supplies a cryptographically verifiable enforcement assertion token (opaque to participants) that demonstrates, at the time of submission, that the order passed the controlling check(s). The covered operator shall verify the token before order acceptance, log the verification result, and reject the order if verification fails. (C) Where (B) is used, the covered operator shall retain, and make available to an assessor on request, an auditable record tying each accepted order to the enforcement assertion (including timestamped assertion token, verifying metadata, and rejection reason codes for attempted orders that failed verification). (D) For running platforms only: where implementation of (A) or (B) requires modification of third‑party gateways, network paths, or client software, the covered operator may adopt documented compensating controls for up to six months from the effective date of this Standard, provided the operator (i) contemporaneously logs every pre‑accepted order, attempted order rejection, and the outcome of any upstream checks, (ii) submits a migration plan to the assessor within thirty days showing how it will implement (A) or (B), and (iii) implements (A) or (B) no later than six months after the effective date. During the transition, the system shall continue to "fail safe" by rejecting orders where a required control is unavailable. Add to §207(a) a new advisory sentence: "As drafted, the requirement in paragraph (a)(2) cannot be satisfied by a venue that merely relies on opaque upstream broker checks without the verifiable linkage and real‑time rejection behaviour described above; assessing compliance requires the artifacts specified in (a)(2)(B)-(C)." Rationale: As drafted, §207(a)(2) mandates enforcement "at the point of order entry" but does not recognise common market structures (sponsored access, external broker gateways, API pre‑validation) where the venue's authoritative order book accepts only pre‑validated orders. Regulators and assessors will examine whether checks were actually enforced before orders affected the book. Requiring either on‑venue enforcement or a minimal, cheap, verifiable token and logging scheme preserves the protection while avoiding wholesale re‑engineering of client software or broker systems immediately. The six‑month transitional allowance aligns a running platform's realistic retrofit window with supervisory expectations while preventing indefinite reliance on post‑hoc review. The added advisory sentence flags the drafting gap for assessors. Cheapest compliant implementation: implement (B) - an acceptance/assertion token validated at order acceptance and recorded in logs - which requires modest gateway software to verify tokens and store verification metadata, rather than replacing upstream broker infrastructure. This is less costly than reworking all client software while meeting the standard's protection goal. Evidence: PMCPS-M §207(a)(2) currently: "enforce every limit, exclusion, and restriction required by these Standards at the point of order entry, and not solely by post‑hoc review." FINRA 2026 report (pre‑trade controls deficiencies) and NYSE March 2026 notice (clarifying many controls are broker‑level and that exchange checks are supplemental) show the standard as drafted ignores real allocation of pre‑trade controls and practical implementation. ESMA statement (MiCA; six‑month expectation for data/telemetry migration) supports the proposed six‑month transitional window for running platforms. (PMCPS-M §207 / FINRA 2026 / NYSE 2026 / ESMA 2025) --- - S006: Amend PMCPS-M §501 and §502 to require a machine‑readable, versioned, and immutably recorded "resolution specification" for every covered contract; clarify the conditions under which an operator may act as the resolution source, and provide the minimal procedural and technical steps that permit listing where no independent source exists. Insert before PMCPS-M §501(a) a new definition in §203(b): "Resolution specification" means a machine‑readable, versioned data object (e.g., JSON) published at contract listing that (i) encodes the precise condition that determines settlement (including any thresholds, normalization, filters, and tie‑breaking rules), (ii) identifies the resolution source(s) by unique identifier and access method (URL, API endpoint, dataset identifier), (iii) states the exact UTC timestamp at which the resolution source will be consulted, and (iv) records fallback procedures if the primary source is unavailable or ambiguous. The resolution specification shall be content‑addressed and its cryptographic hash recorded in the contract's immutable listing record. Replace PMCPS‑M §501(a) and add a new §501(d) as follows (edits shown as replacement & addition): (a) A covered operator shall, before listing a covered contract and continuously thereafter, publish for that contract a resolution specification satisfying the definition in §203(b), including: (1) the precise condition that determines settlement, expressed in the resolution specification so that outcome can be determined by applying the specification to the identified resolution source without discretionary interpretation by the covered operator where feasible; (2) the resolution source identified specifically and by unique identifier suitable for machine access; (3) the exact time (in UTC) at which the resolution source will be consulted; (4) the treatment of the contract if the resolution source does not publish, publishes ambiguously, or ceases to exist, encoded as a deterministic fallback algorithm where feasible; (5) the treatment of the contract if the underlying event is cancelled, postponed beyond a stated date, or materially altered; and (6) the treatment of the contract if the resolution source revises its determination after settlement. (d) A covered operator shall refuse to list a covered contract unless the resolution specification either (i) encodes an unambiguous, machine‑executable determination rule that can be applied to the identified resolution source(s), or (ii) where an unambiguous machine rule is not feasible, the operator designates in the specification a pre‑identified independent adjudicator or panel and an unambiguous review standard and publishes the adjudicator's commitment to be bound by that standard. Where the operator is itself the designated adjudicator under (ii), the operator must disclose that fact at point of order entry, and the determination shall be subject to post‑settlement independent review under §504 by a person independent of the operator. Amend PMCPS‑M §502(c) to require machine publication and retention: (c) Where no independent resolution source exists for an event, a covered operator may determine the outcome only if it (1) discloses in the resolution specification that it is the resolution source, prominently and at the point of order entry; (2) publishes in the resolution specification the evidence it will consider and the review standard it will apply; (3) publishes its determination with the reasoning and the evidence relied on; (4) records the evidence and reasoning in an append‑only, timestamped record and submits determinations under this paragraph to review under §504. Add to PMCPS‑M §505(a) a new requirement to attach the resolution specification hash to the contract review documentation retained under §601. Transitional provision: A covered operator shall implement machine‑readable resolution specifications for all newly listed contracts on or before six months after the effective date of this Standard and shall convert existing listed contracts' resolution criteria to resolution specifications within nine months. During conversion the operator shall publish a human‑readable resolution statement and the interim mapping to the machine specification; after nine months, listings without a resolution specification shall be delisted. Rationale: §501(a)(1) currently requires the settlement condition be "stated so that a reasonable participant can determine the outcome from the resolution source without exercise of judgment by the covered operator." Many real‑world resolution sources and event definitions are ambiguous or require human judgment; as drafted, the standard is vague about how to demonstrate "no exercise of judgment" and how assessors can verify compliance. Requiring a machine‑readable, versioned resolution specification and recording its content‑addressed hash with the listing produces a cheap, auditable artifact that proves what was promised at listing, enables automated settlement where possible, and makes post‑settlement review practical. Where machine determinism is impossible, designating an independent adjudicator and encoding review standards is the least‑cost mitigation that preserves participant transparency and assessor verifiability. The transitional timeline (6/9 months) gives running platforms a concrete retrofit window consistent with supervisory practice on data/format migrations. Cheapest compliant implementation: use a simple JSON schema for the resolution specification (fields: settlement_condition_expression, resolution_source_id, resolution_timestamp_utc, fallback_algorithm, adjudicator_id, spec_version) and store its SHA‑256 hash in the contract metadata and audit logs. This requires minimal engineering (publishable file + hash + link in listing) and scales far cheaper than bespoke human‑review workflows. Evidence: PMCPS‑M §501(a)(1) and §502(c) currently impose vagueness: "stated so that a reasonable participant can determine the outcome from the resolution source without exercise of judgment by the covered operator" and limited procedural detail for operator as resolution source. Appendix A item 4 in PMCPS‑M invites comment on operator as resolution source (open question). The ESMA MiCA statement (mandating specific data fields and timestamps and giving six months' expectation for adoption) supports requiring machine‑readable specifications and a concrete migration window. The novelty and risk in PART 500's prefatory note (lack of precedent; ambiguous sources) directly motivates machine‑readable specs and recorded hashes to make post‑listing settlement decisions auditable.

The Participant Advocate (openai:gpt-5-mini) - S007: Amend PMCPS-M § 501 and related system/settlement provisions as follows: - Add to § 501(a) a new paragraph (7) requiring that the operator present the following facts to the participant at the point of order entry (i.e., on the order-entry screen before the participant submits the order) and in the order confirmation message: - the precise, machine-identifiable resolution source (name and URL or unique identifier); - the single-sentence plain‑language settlement condition derived from § 501(a)(1) that will be applied to that source; - the exact time or deadline when the resolution source will be consulted (§ 501(a)(3)); - whether the resolution source is independent of the operator or is the operator/affiliate or a person compensated by the operator; - whether that resolution source (or the contract type) is under a known regulatory review or subject to a group prohibition or stay. - Add to § 501(c) (amendment prohibition) a sentence: “An operator shall not change the resolution source after a participant has submitted an order for that contract, except to correct a manifest error under § 503(b). If the operator changes the resolution source after orders are executed, the operator must (i) notify affected participants within 24 hours and (ii) permit affected participants to close or reduce their positions without fee for a period of 48 hours following notice.” - Amend § 504 to specify that a participant may contest a settlement within 14 calendar days of publication of the settlement value; upon filing a contest under § 504(a) the participant may request a provisional administrative hold on contested settlement proceeds pending resolution of the dispute, and the operator shall grant such a hold until the contest is resolved or the hold period expires pursuant to the operator’s published procedure. Apply corresponding edits to PMCPS-C § 105(b)(3) to require that the classification record identify the precise resolution source in the form required by the new § 501(a)(7), so the classification record and participant disclosure use identical identifiers. Rationale: Participants cannot make informed pre‑trade choices unless they know exactly which source and criteria will decide their money and when that source will be consulted. Without this information at the moment they place an order, participants cannot avoid contracts resolved by operator‑controlled or contested sources, nor can they meaningfully decide to refuse a product whose resolution mechanism is under regulatory review. Requiring this fact at order entry gives participants an actionable choice (decline trade, set preference not to trade operator‑resolved contracts, or use limits/exclusion) and prevents operators from changing settlement mechanics after accepting money without giving participants a real exit. Specifying a 14‑day contest window and provisional hold turns the existing contest procedure (§ 504) into an actionable remedy participants can use to preserve funds while a dispute is decided. Evidence: PMCPS-M § 501 already requires publishing resolution criteria and § 502(c) requires disclosure where the operator is the source, but those provisions are limited to “publish” and (in § 502(c)(1)) “prominently and at the point of order entry” only when the operator is the source. The CFTC Division of Market Oversight advisory (Letter No. 26‑08) and the CFTC proposed Public Interest Determinations rule emphasize pre‑trade identification of settlement sources and the need for contestability; the CFTC proposed rule also contemplates disclosure where a contract type is under review. PMCPS-C § 105(b)(3) already records the resolution source for classification determinations - aligning that record form with participant disclosure removes ambiguity about which source was intended. --- - S008: Amend PMCPS-M § 301, § 302, and § 403 to require specific, timed participant-facing controls and facts at registration, at first deposit, on first order entry, and on login when location changes: - Add to § 301(a) and § 302(c) that at (1) account registration, (2) the first deposit, and (3) on the order-entry screen before the participant submits a first order in any covered contract, the operator must present a non-dismissable modal that states, as facts: - the participant’s verified minimum‑age status (pass/fail) and the minimum age applied; - whether the participant’s current jurisdiction permits the participant to trade the specific covered contract(s) offered (Yes/No). If No, the modal must state that trading is blocked and provide the actions the participant may take (close positions, cancel resting orders, withdraw funds) and the means to do so. - a concise list of available self‑exclusion terms (one year, five years, lifetime) and direct one‑click controls to enroll immediately without contacting customer service; - the three limit types (deposit, spend, loss) and session time limit with one‑click controls to set each immediately (durations 24h, 7d, 1 month) and a one‑click 72‑hour suspension option. - Amend § 302(c) to require the operator to enforce these modal controls so that a participant may not submit their first order in a covered contract until they have either (i) set limits or self‑exclusion via the modal, or (ii) affirmatively chosen “proceed without setting limits” by checking a box acknowledging the risk of total loss (this acknowledgement must be recorded). - Add to § 403(c) that when the participant’s detected location indicates a jurisdiction where the operator is not authorized to offer the specific covered contract, the operator shall present the same modal at login and shall block order entry for that contract type; the operator shall not route, proxy, or otherwise attempt to permit trading from that location by routing through affiliates or third parties. Rationale: Participants must be given the concrete tools to limit exposure or exclude themselves at predictable, high‑impact moments (registration, first deposit, first order). PMCPS‑M currently requires availability of exclusion and limits (§ 301, § 302) and prompts at registration or first deposit (§ 302(c)), but it does not mandate that these facts and controls be presented as an actionable modal that must be acted on before the first trade. Specifying the moments and the one‑click controls prevents operators from burying enrollment or limits behind customer service, marketing, or later screens; it gives participants an immediate ability to reduce harm before any money is placed at risk. Requiring a jurisdictional block modal at login when location changes operationalizes the obligations exposed by the Washington State injunction intel and prevents routing workarounds that would defeat participant protections. Evidence: PMCPS-M § 301 already requires that enrollment in exclusion be available “at any time” and without contacting customer service, and § 302(c) already requires prompting to set limits at registration or first deposit - but neither mandates the specific timing (registration, first deposit, first order) nor the non‑dismissable, one‑click control. The Washington State AG injunction against Kalshi demonstrates the practical need to disclose and block jurisdictionally prohibited trading at login and before order submission. The Prediction Market Act of 2026 (Senators McCormick & Gillibrand) and the National Council on Problem Gambling call for onboarding self‑exclusion and limits, age minimums, and ready access to play history and helplines; this proposal operationalizes those protections at the exact moments participants decide to trade.

The Settlement and Integrity Specialist (claude:claude-sonnet-5) - S009: Amend PMCPS-M § 402 by adding a new subsection (g): "A covered operator shall log each instance in which an individual is matched against, added to, or blocked by the restricted list maintained under subsection (e), recording the date, the covered contract concerned, and the action taken. This log shall be retained under § 601(a) and produced on request to an assessor or applicable regulatory authority." Correspondingly amend § 601(a)(5) to read "documentation under § 402(c), the screening log under § 402(g), and § 505(a) for each covered contract listed." Rationale: § 402(a) obligates the operator to "employ commercially reasonable methods to prevent an influencing person from entering into a covered contract," and § 402(e) requires it to "maintain a restricted list" and "screen accounts against it," but nothing in Part 400 or § 601 requires evidence that screening actually occurred or produced any hits, blocks, or denials. § 601(a)(5) retains only the pre-listing documentation of categories and methods under § 402(c), which proves a plan existed, not that it was executed. An assessor examining § 402 today has no record from which to verify the operator's ongoing performance against its own restricted list, only its stated intent. This is precisely the "obligation without evidence" defect the mission flags as priority. Evidence: PMCPS-M § 402(a), (c), (e); § 601(a)(5) as currently drafted retains only § 402(c)/§ 505(a) documentation. The CFTC Kaptur disciplinary action (Feb. 25, 2026) shows that exchange-level identification and restriction of influencing persons is an operational, evidentiary matter distinct from having a written policy; an assessor should be able to confirm from records, not representations, that the restricted-list mechanism identified in § 402(b)-(e) was actually applied to the individual concerned. - S010: Amend PMCPS-M § 503 to add a distinct correction ground for resolution-source revision, separate from manifest error. Insert new § 503(b-1): "A covered operator may also correct a settlement where the resolution source itself revises the factual determination on which the settlement relied, provided the correction is made within the period published under § 501(a)(6), is published with the source's revised determination and the operator's basis for reliance on it, and is reported under § 603." Amend § 503(c) to read: "...where the published criteria were correctly applied to the resolution source's determination as it stood at settlement, and no revision under paragraph (b-1) has occurred." Rationale: § 501(a)(6) requires an operator to publish, before listing, "the treatment of the contract if the resolution source revises its determination after settlement" - meaning the standard contemplates this scenario as real and expects a stated policy. But § 503(b) defines the only correction ground as "manifest error," meaning "a demonstrable failure to apply the published resolution criteria to the published resolution source" - i.e., the operator's own misapplication, not a subsequent change by the source itself. § 503(c) then separately bars reversal on the ground "that the resolution source was mistaken... where the published criteria were correctly applied." Read together, an operator that correctly applied criteria to the source's determination as it stood at settlement is barred from correcting even where the source itself later revises its determination, yet § 501(a)(6) demands the operator publish a "treatment" for that exact event. The standard requires a policy for a scenario it simultaneously forecloses any operative rule for. This is not a drafting nicety; it is the gap that materialized in the Polymarket/MicroStrategy dispute. Evidence: PMCPS-M § 501(a)(6); § 503(b)-(c). Intel: Cointelegraph, "Polymarket dispute over MicroStrategy sale resolves 'No,' sparking governance concerns" (June 4, 2026) - a market resolved against a later-confirmed 8-K showing the triggering sale occurred, with no distinct mechanism for source-revision correction separate from ordinary error review. Economics Letters (2026), "Do prediction markets price events or adjudication?" - finding that in disputed oracle-settled markets, settlement-window prices track the adjudicator's decision rather than the audited-correct outcome, and that the adjudicating vote overturns the audited-correct outcome in a non-trivial share of cases, evidencing the systemic risk of leaving source-revision unaddressed as a correction category.

The Minimal Intervention Advocate (openai:gpt-5-mini) - S011: Amend PMCPS-C § 104(d)(1) and PMCPS-C § 106 to narrow the commodity/index carve-out and add an explicit review trigger: - Replace current § 104(d)(1) with: "A product whose payout is the continuous, point-in-time price, rate, level, or index value of a commodity, security, or index (i.e., the contract settles at the underlying level rather than by reference to a discrete threshold or occurrence) is excluded from this Standard; binary, threshold, or otherwise discretized contracts that pay on whether an underlying price, rate, or index crosses a stated threshold remain subject to the test in § 104. The exclusion applies only where the contract's settlement mechanism and economic characteristics make it substantially equivalent to a regulated financial instrument whose primary regulatory framework governs continuous-price settlement." (Retain remainder of § 104.) - Add to § 106 a reclassification trigger: "A covered operator shall re-apply the § 104 determination, and an assessor shall re-examine any reliance on § 104(d)(1), whenever a materially relevant change in federal or other applicable law or market practice affecting continuous-price financial instruments occurs; the operator shall document the analysis used to determine equivalence or non-equivalence." What this does to PMCPS-M: PMCPS-M § 202(b) continues to take applicability from PMCPS-C § 104; narrowing § 104(d)(1) reduces the set of products to which PMCPS-M applies (i.e., binary/threshold price contracts remain in scope while continuous-price instruments that are functionally financial remain excluded). Operators relying on the § 104(g)(1) equivalence exclusion must maintain the reclassification record required by PMCPS-C § 105 and the new re-examination documentation under § 106. Rationale: The existing categorical carve-out in § 104(d)(1) is broader than the functional distinction that matters to participant protection and to duplicative regulation. The hard borderline called out in Appendix C item 1 (binary threshold vs. continuous-price settlement) is the single most contested boundary and currently risks both (a) leaving economically equivalent consumer-facing threshold products outside consumer protections simply because an underlying is an "index" or "price," and (b) sweeping genuinely fungible financial instruments (continuous-price contracts) into PMCPS scope where they sit more appropriately under financial-market rules. Narrowing the carve-out to continuous-price instruments that are economically equivalent to regulated financial products preserves PMCPS protections where they are needed (discretized/threshold event exposures) while avoiding duplicative supervision of instruments whose principal risk-profile and settlement mechanics are that of regulated financial instruments. Adding a reclassification trigger makes the record-driven, evidence-based approach explicit and prevents permanent misclassification where law or markets change. Evidence: PMCPS-C § 104(d)(1) (current text and Appendix C item 1 identifies this as the hardest case); PMCPS-C § 105 and § 106 (classification record and reclassification provisions) provide the mechanism for documenting determinations; CFTC ANPRM and Federal Register materials show regulatory attention to functional classification and support a move to a functional, evidence-based line rather than a bright-line label (Federal Register: CFTC Proposed Rule on Prediction Markets, June 12, 2026). This suggestion engages Appendix C item 1 (allowed as one open-question change). --- - S012: Remove the mandatory external independent-integrity-monitor requirement in PMCPS-M § 405(b) and replace it with a disclosure-plus-assessor-review regime and an evidence-driven sunset/reinstatement clause: - Delete PMCPS-M § 405(b) in its current form. Replace with a new § 405(b) that reads: "A covered operator shall maintain and operate automated surveillance sufficient to detect the conduct prohibited by § 401 and shall publicly disclose, at the point of first order entry and in the persistent disclosures required by § 303, (1) the existence of its surveillance function, (2) the categories of activity it monitors, and (3) the process by which it reports potential misconduct to an assessor and any applicable regulatory authority. The operator shall make surveillance methodology, data retention practices, and sampling results available for confidential review by the assessor required under § 604. Where an assessor or an applicable regulatory authority finds material gaps in the operator's surveillance or reporting, the assessor or authority may require reinstatement of an independent integrity monitor under terms it specifies; the operator shall comply while corrective measures are implemented." When this changes PMCPS-M elsewhere: This substitution preserves PMCPS-M § 405(a) (automated surveillance), § 603 (incident reporting), § 701 (assessor competence), § 602 and § 604 (periodic reporting and audits/assessor review) as the primary verification points. It removes the prescriptive, across-the-board external-monitor mandate and instead ties any external-monitor requirement to demonstrated gaps found in assessor review or regulator action. Rationale: § 405(b)'s current prescriptive mandate (external, non-affiliate integrity monitor with broad duties) was written to prevent manipulation, undetected cross-platform misconduct, and conflicts of interest. Those harms are real, but the standard as drafted mandates a specific structural cure without demonstrating that an external monitor is the only or best way to achieve detection and mitigation. The same harms are already addressed by (a) the surveillance requirement in § 405(a), (b) incident reporting under § 603, (c) independent testing and system certification under § 208, (d) assessor competence and periodic assessments in §§ 701 and 604, and (e) the enforcement/anti-fraud backstop described in PMCPS-M § 401 and supported by existing law (see Evidence). Substituting transparent operator disclosure of surveillance scope plus mandatory assessor access aligns the remedy to the function: preserve price-discovery instruments by keeping surveillance and detection local and auditable, while giving assessors/regulators the authority to require an external monitor only where evidence shows the operator's processes are insufficient. Add a reinstatement pathway (sunset-style: external monitor only if evidence requires) so the prescriptive structural cure must earn its place. Evidence: PMCPS-M § 405(a) (automated surveillance requirement), § 603 (incident reporting), § 208 (independent testing), § 701 and § 604 (assessor competence and audits) already create multiple evidentiary layers for detecting manipulation; PMCPS-M § 401 states the prohibited conduct the monitor was aimed to prevent. The CFTC Division of Enforcement Advisory (Feb. 25, 2026) documents that existing anti-fraud and market-manipulation law (CEA § 6(c)(1) and Rule 180.1) has been used to address insider misuse, fraud, wash trades, and disruptive practices-supporting substitution of disclosure plus assessor review for blanket external-monitor mandates.

2. Pool Phase

Leader actions: - 12 suggestion(s) retained as submitted

Final pool: 12 suggestions (from 12 submitted; 0 merged)

• S001: Replace PMCPS-M §208 with the following instructional text and evidence requirements (and where the covered operator is a registered designated contract market (DCM) under the Commodity Exchange Act, substitute the alternative compliance pathway stated below): - PMCPS-M §208 Independent testing - mandatory evidence and DCM alternative (a) For a covered operator that is not a registered DCM: the covered operator shall obtain and retain written certification from an independent testing laboratory that its systems satisfy §207. The independent testing laboratory report shall, at minimum, include: (1) a statement of the laboratory's independence and lack of prior design/implementation role; (2) the scope of testing mapped to each §207 obligation tested (including itemized test cases that demonstrate point-of-entry enforcement of limits and exclusions, rejection-on-failure behavior, timestamp fidelity, activity-history reconstruction, and excluded-participant blocking); (3) test procedures and pass/fail results, including dates, system build version(s) tested, and a list of any test exceptions; (4) evidence of remediation for each exception (remediation plan, remediation completion evidence, and retest results); (5) a vulnerability/penetration test summary and any critical findings with mitigation evidence; and (6) the date of report, signature/attestation by the lead tester, and retention of raw test artifacts for five years. (b) Evidence to be produced to an assessor or applicable regulatory authority: the full testing report required under paragraph (a), the remediation records, and a copy of the independent laboratory's credentials and scope of accreditation. (c) Certification frequency and triggers: certification shall be renewed at least every two years and also upon any material change to the systems under §207(b). Evidence of renewal or of a material-change retest shall be the testing report described in paragraph (a). (d) DCM alternative compliance pathway (replacement text where a covered operator is a registered DCM): a DCM may satisfy paragraphs (a)-(c) by producing, in lieu of a separate independent laboratory report, the contemporaneous testing, attestation, and submissions required by the Commodity Exchange Act and 17 C.F.R. (including system safeguard testing and attestations performed under 17 C.F.R. §§ 38.1050-38.1051, Part 38 system certification/attestation artifacts, and any Part 40 self‑certification materials that include product/system testing). The DCM must produce: (1) the filings made to the Commission (date-stamped copies) and any independent lab reports relied upon in those filings; (2) the internal test plans and post-change test results mapping to PMCPS-M §207 obligations; and (3) remediation evidence and the working papers necessary to verify the testing conclusions. (e) Where there is any divergence between the testing scope required by Part 38 (or other CFTC obligations) and the items mapped to PMCPS-M §207, the covered operator shall supply the additional test artifacts necessary to demonstrate compliance with each PMCPS-M §207 element not covered by the CFTC filings. (f) Retention: all reports and raw test evidence required by this section shall be retained for five years and produced to an assessor or any applicable regulatory authority on request.
• S002: Amend PMCPS-M §405 and add a new paragraph specifying minimum documentary evidence of surveillance and independent integrity monitoring; and add a narrow DCM-specific reporting alignment clause. Replace current §405(b) with the following text: - PMCPS-M §405 Surveillance and independent integrity monitoring - evidence and DCM alignment (a) Surveillance program evidence. A covered operator shall maintain a documented automated surveillance program sufficient to detect the prohibited conduct in §401. For each surveillance rule or analytic used the operator shall retain and produce on request: (1) the written surveillance policy and rulebook (including rule purpose and detection logic); (2) the historical threshold/configuration values and change log (who changed, when, and why); (3) alert logs showing each triggered alert, time-stamped analyst notes, inquiries opened, and final disposition; (4) a sample of surveillance output demonstrating detection of at least one true positive and one false positive, with corresponding remediation or tuning records; and (5) weekly and monthly exception reports for the prior twelve months, and metrics on mean time to detect and mean time to respond. (b) Independent integrity monitor - contract and product evidence. The covered operator shall contract with an independent integrity monitor and shall retain and produce: (1) the contract or engagement letter specifying independence, scope, deliverables, reporting cadence, confidentiality protections, and escalation paths (including obligations to report to applicable authorities); (2) the monitor's written methodology for trade and conduct surveillance and data access to trading and resolution artifacts; (3) copies of all integrity-monitor reports issued during the prior twelve months (redactions permitted only for personally identifying information where required by law), and evidence that the covered operator acted on corrective recommendations (remediation plans and completion evidence); (4) the monitor's personnel qualifications and documented training program; and (5) records of information-sharing with other monitors where relevant to cross-platform conduct. (c) DCM alignment and Commission reporting. Where the covered operator is a registered DCM: (1) the operator may satisfy paragraphs (a)-(b) by producing the surveillance program, surveillance logs, monitoring reports, and any materials sent or required to be made available to the Commission under 17 C.F.R. Part 38 and related directives (including evidence supporting continuous/24/7 monitoring and staffing per CFTC Staff Advisory 26-16); (2) if a DCM's rules or monitoring activity are the subject of a Commission stay or directive (for example as in CFTC Press Release 9267-26), the covered operator shall contemporaneously produce the Commission directive and evidence of compliance with it to the assessor together with the surveillance records required herein. (d) Confidentiality. Integrity monitoring reports and surveillance logs are confidential but shall be produced to an assessor and to any applicable regulatory authority on request; the operator shall document the legal basis for any redactions.
• S003: Amend PMCPS-M § 301(d) and related recordkeeping paragraphs to require both immediate allowance of risk‑reducing exit orders for an excluded participant and a one‑time, optional participant‑initiated liquidation offer at a transparent reference price. Insert the following text as new subparagraphs to § 301(d) and add recordkeeping obligations to § 601: - New § 301(d)(5): "In addition to permitting risk‑reducing orders, a covered operator shall offer each newly enrolled excluded participant, at enrollment and for thirty calendar days thereafter, a one‑time optional liquidation transaction that, if elected by the participant, will attempt to close the participant's open positions at a firm reference price. The operator shall present the option in the same enrollment flow that confirms exclusion and shall not require additional customer service contact." - New § 301(d)(6): "The reference price for the optional liquidation shall be the mid‑market price (the arithmetic mean of the best bid and best ask) displayed in the covered operator's continuous order book at the time the participant elects the liquidation, unless the participant elects a time‑weighted average price (TWAP) over a period of not less than five minutes. The operator shall execute the liquidation as a single marketable order against live liquidity and shall not impose a fee, charge, or penalty on the liquidation proceeds. If the order is not marketable within sixty seconds the operator shall cancel the offered liquidation and notify the participant; the participant retains the right to place risk‑reducing orders under § 301(d)(1)." - New § 301(d)(7): "The operator shall include conspicuous pre‑election disclosure of (i) the mechanics of the optional liquidation, (ii) the reference‑price method to be used, (iii) the risk that the reference price may differ from prices realized in the market, and (iv) that acceptance of the optional liquidation is binding." - Amend § 601(a) to add new record items retained for not less than five years: "(10) a record of the offer of the one‑time optional liquidation, whether it was accepted or declined, the reference price quoted, execution records if accepted, and notifications sent; (11) logs demonstrating that risk‑reducing orders by an excluded participant were accepted and executed, including timestamps and execution receipts." Apply consequential edits to PMCPS-C §105(d)/(e) only to reference retention and production obligations already required in PMCPS-M §601 for these records.
• S004: Require pre‑listing filing of classification determinations and expand mandatory reporting and retention of exclusion/problem‑gambling metrics to match current state operator practice (Nevada, New Jersey, Ohio). Implement the following edits: 1. Amend PMCPS-C §105: - Replace § 105(a)-(e) with text requiring that, for any product the covered operator intends to offer to participants located in a jurisdiction that has adopted these Standards or to participants resident in a jurisdiction where the operator relies on a gaming licence equivalence under § 104(g)(1), the covered operator must file the written classification determination required by § 105 with the applicable regulatory authority and with its assessor at least fourteen calendar days before the product is first offered in that jurisdiction. The filing must include all items listed in § 105(b) and any material supporting documentation. The operator must update the filing within seven calendar days of any reclassification event under § 106. - Retain the five‑year retention obligation but add that the filing copy must be retained and made available to any adopting regulatory authority for not less than five years after the product is last offered. 2. Amend PMCPS-M § 304 (problem gambling plan) and § 303(a)(8), and expand § 602 reporting and § 601 records: - New PMCPS-M § 304(a)(10): "The problem gambling plan shall designate an RG (Responsible Gaming) Lead with contact information, specify data‑driven 'RG triggers' (for example: cumulative deposits, turnover thresholds, frequency of withdrawals/reversals, frequency of login/session duration, and repeated self‑exclusion page access), and document the phased interventions to be applied when a trigger is met." - New PMCPS-M § 304(b) (expanded reporting): "A covered operator shall submit quarterly to its assessor and to any applicable regulatory authority: (i) the number of participants identified by each RG trigger and the remediation steps taken; (ii) the number of 'at‑risk' patrons added to an operator list, the basis for that determination, and the number not deemed at‑risk together with a written explanation retained for five years; and (iii) confirmation that marketing suppression and account restrictions were applied within fifteen calendar days of exclusion enrollment." - Amend PMCPS-M § 303(a)(8) to require that problem‑gambling help resources include, where required by the adopting authority, the helpline number designated by that authority and that the operator shall update the number within seven calendar days of any regulatory notice (e.g., Nevada Gaming Control Board Notice 2025‑74). - Expand PMCPS-M § 602(a) to add quarterly reporting items: "(7) number of participants flagged by RG triggers, actions taken, and number of participants for whom the operator declined to designate 'at‑risk' with the operator's five‑year retained explanation; (8) the number and timing of marketing suppression actions and evidence of suppression (suppression logs); (9) the number of exclusion enrollments by term and the number of orders and deposit attempts blocked, plus the number and type of exit/closing orders executed by excluded participants (including one‑time liquidations under §301)." - Amend PMCPS-M § 601(a)(3) and (9) to specify retention of marketing suppression logs, the RG trigger event logs, and five‑year retained explanations when a flagged patron is not designated at‑risk.
• S005: Amend PMCPS-M §207(a)(2) and add transitional and implementation paragraphs to recognise realistic market structure and to define the least‑cost, verifiable means a running platform may use to meet the "point of order entry" enforcement requirement. Replace §207(a)(2) with the following text and add new paragraphs (a)(2)(A)-(D): (2) enforce every limit, exclusion, and restriction required by these Standards at the point of acceptance of an order into the covered operator's authoritative order book ("order acceptance"), and not rely solely on post‑hoc review. Where the covered operator's technology or market structure results in an upstream order‑submission path (including third‑party gateways, sponsored access, or pre‑validated order feeds) such that enforcement may occur upstream of the covered operator's order acceptance, the covered operator shall satisfy paragraph (a)(2) by one of the following verifiable means: (A) Direct enforcement at order acceptance: the covered operator's venue enforces the control prior to accepting the order into its authoritative order book, rejecting non‑compliant orders in real time with a rejection code indicating the control triggered. (B) Upstream assertion with verifiable acceptance token: the covered operator accepts pre‑validated orders only where the submitting party supplies a cryptographically verifiable enforcement assertion token (opaque to participants) that demonstrates, at the time of submission, that the order passed the controlling check(s). The covered operator shall verify the token before order acceptance, log the verification result, and reject the order if verification fails. (C) Where (B) is used, the covered operator shall retain, and make available to an assessor on request, an auditable record tying each accepted order to the enforcement assertion (including timestamped assertion token, verifying metadata, and rejection reason codes for attempted orders that failed verification). (D) For running platforms only: where implementation of (A) or (B) requires modification of third‑party gateways, network paths, or client software, the covered operator may adopt documented compensating controls for up to six months from the effective date of this Standard, provided the operator (i) contemporaneously logs every pre‑accepted order, attempted order rejection, and the outcome of any upstream checks, (ii) submits a migration plan to the assessor within thirty days showing how it will implement (A) or (B), and (iii) implements (A) or (B) no later than six months after the effective date. During the transition, the system shall continue to "fail safe" by rejecting orders where a required control is unavailable. Add to §207(a) a new advisory sentence: "As drafted, the requirement in paragraph (a)(2) cannot be satisfied by a venue that merely relies on opaque upstream broker checks without the verifiable linkage and real‑time rejection behaviour described above; assessing compliance requires the artifacts specified in (a)(2)(B)-(C)."
• S006: Amend PMCPS-M §501 and §502 to require a machine‑readable, versioned, and immutably recorded "resolution specification" for every covered contract; clarify the conditions under which an operator may act as the resolution source, and provide the minimal procedural and technical steps that permit listing where no independent source exists. Insert before PMCPS-M §501(a) a new definition in §203(b): "Resolution specification" means a machine‑readable, versioned data object (e.g., JSON) published at contract listing that (i) encodes the precise condition that determines settlement (including any thresholds, normalization, filters, and tie‑breaking rules), (ii) identifies the resolution source(s) by unique identifier and access method (URL, API endpoint, dataset identifier), (iii) states the exact UTC timestamp at which the resolution source will be consulted, and (iv) records fallback procedures if the primary source is unavailable or ambiguous. The resolution specification shall be content‑addressed and its cryptographic hash recorded in the contract's immutable listing record. Replace PMCPS‑M §501(a) and add a new §501(d) as follows (edits shown as replacement & addition): (a) A covered operator shall, before listing a covered contract and continuously thereafter, publish for that contract a resolution specification satisfying the definition in §203(b), including: (1) the precise condition that determines settlement, expressed in the resolution specification so that outcome can be determined by applying the specification to the identified resolution source without discretionary interpretation by the covered operator where feasible; (2) the resolution source identified specifically and by unique identifier suitable for machine access; (3) the exact time (in UTC) at which the resolution source will be consulted; (4) the treatment of the contract if the resolution source does not publish, publishes ambiguously, or ceases to exist, encoded as a deterministic fallback algorithm where feasible; (5) the treatment of the contract if the underlying event is cancelled, postponed beyond a stated date, or materially altered; and (6) the treatment of the contract if the resolution source revises its determination after settlement. (d) A covered operator shall refuse to list a covered contract unless the resolution specification either (i) encodes an unambiguous, machine‑executable determination rule that can be applied to the identified resolution source(s), or (ii) where an unambiguous machine rule is not feasible, the operator designates in the specification a pre‑identified independent adjudicator or panel and an unambiguous review standard and publishes the adjudicator's commitment to be bound by that standard. Where the operator is itself the designated adjudicator under (ii), the operator must disclose that fact at point of order entry, and the determination shall be subject to post‑settlement independent review under §504 by a person independent of the operator. Amend PMCPS‑M §502(c) to require machine publication and retention: (c) Where no independent resolution source exists for an event, a covered operator may determine the outcome only if it (1) discloses in the resolution specification that it is the resolution source, prominently and at the point of order entry; (2) publishes in the resolution specification the evidence it will consider and the review standard it will apply; (3) publishes its determination with the reasoning and the evidence relied on; (4) records the evidence and reasoning in an append‑only, timestamped record and submits determinations under this paragraph to review under §504. Add to PMCPS‑M §505(a) a new requirement to attach the resolution specification hash to the contract review documentation retained under §601. Transitional provision: A covered operator shall implement machine‑readable resolution specifications for all newly listed contracts on or before six months after the effective date of this Standard and shall convert existing listed contracts' resolution criteria to resolution specifications within nine months. During conversion the operator shall publish a human‑readable resolution statement and the interim mapping to the machine specification; after nine months, listings without a resolution specification shall be delisted.
• S007: Amend PMCPS-M § 501 and related system/settlement provisions as follows: - Add to § 501(a) a new paragraph (7) requiring that the operator present the following facts to the participant at the point of order entry (i.e., on the order-entry screen before the participant submits the order) and in the order confirmation message: - the precise, machine-identifiable resolution source (name and URL or unique identifier); - the single-sentence plain‑language settlement condition derived from § 501(a)(1) that will be applied to that source; - the exact time or deadline when the resolution source will be consulted (§ 501(a)(3)); - whether the resolution source is independent of the operator or is the operator/affiliate or a person compensated by the operator; - whether that resolution source (or the contract type) is under a known regulatory review or subject to a group prohibition or stay. - Add to § 501(c) (amendment prohibition) a sentence: “An operator shall not change the resolution source after a participant has submitted an order for that contract, except to correct a manifest error under § 503(b). If the operator changes the resolution source after orders are executed, the operator must (i) notify affected participants within 24 hours and (ii) permit affected participants to close or reduce their positions without fee for a period of 48 hours following notice.” - Amend § 504 to specify that a participant may contest a settlement within 14 calendar days of publication of the settlement value; upon filing a contest under § 504(a) the participant may request a provisional administrative hold on contested settlement proceeds pending resolution of the dispute, and the operator shall grant such a hold until the contest is resolved or the hold period expires pursuant to the operator’s published procedure. Apply corresponding edits to PMCPS-C § 105(b)(3) to require that the classification record identify the precise resolution source in the form required by the new § 501(a)(7), so the classification record and participant disclosure use identical identifiers.
• S008: Amend PMCPS-M § 301, § 302, and § 403 to require specific, timed participant-facing controls and facts at registration, at first deposit, on first order entry, and on login when location changes: - Add to § 301(a) and § 302(c) that at (1) account registration, (2) the first deposit, and (3) on the order-entry screen before the participant submits a first order in any covered contract, the operator must present a non-dismissable modal that states, as facts: - the participant’s verified minimum‑age status (pass/fail) and the minimum age applied; - whether the participant’s current jurisdiction permits the participant to trade the specific covered contract(s) offered (Yes/No). If No, the modal must state that trading is blocked and provide the actions the participant may take (close positions, cancel resting orders, withdraw funds) and the means to do so. - a concise list of available self‑exclusion terms (one year, five years, lifetime) and direct one‑click controls to enroll immediately without contacting customer service; - the three limit types (deposit, spend, loss) and session time limit with one‑click controls to set each immediately (durations 24h, 7d, 1 month) and a one‑click 72‑hour suspension option. - Amend § 302(c) to require the operator to enforce these modal controls so that a participant may not submit their first order in a covered contract until they have either (i) set limits or self‑exclusion via the modal, or (ii) affirmatively chosen “proceed without setting limits” by checking a box acknowledging the risk of total loss (this acknowledgement must be recorded). - Add to § 403(c) that when the participant’s detected location indicates a jurisdiction where the operator is not authorized to offer the specific covered contract, the operator shall present the same modal at login and shall block order entry for that contract type; the operator shall not route, proxy, or otherwise attempt to permit trading from that location by routing through affiliates or third parties.
• S009: Amend PMCPS-M § 402 by adding a new subsection (g): "A covered operator shall log each instance in which an individual is matched against, added to, or blocked by the restricted list maintained under subsection (e), recording the date, the covered contract concerned, and the action taken. This log shall be retained under § 601(a) and produced on request to an assessor or applicable regulatory authority." Correspondingly amend § 601(a)(5) to read "documentation under § 402(c), the screening log under § 402(g), and § 505(a) for each covered contract listed."
• S010: Amend PMCPS-M § 503 to add a distinct correction ground for resolution-source revision, separate from manifest error. Insert new § 503(b-1): "A covered operator may also correct a settlement where the resolution source itself revises the factual determination on which the settlement relied, provided the correction is made within the period published under § 501(a)(6), is published with the source's revised determination and the operator's basis for reliance on it, and is reported under § 603." Amend § 503(c) to read: "...where the published criteria were correctly applied to the resolution source's determination as it stood at settlement, and no revision under paragraph (b-1) has occurred."
• S011: Amend PMCPS-C § 104(d)(1) and PMCPS-C § 106 to narrow the commodity/index carve-out and add an explicit review trigger: - Replace current § 104(d)(1) with: "A product whose payout is the continuous, point-in-time price, rate, level, or index value of a commodity, security, or index (i.e., the contract settles at the underlying level rather than by reference to a discrete threshold or occurrence) is excluded from this Standard; binary, threshold, or otherwise discretized contracts that pay on whether an underlying price, rate, or index crosses a stated threshold remain subject to the test in § 104. The exclusion applies only where the contract's settlement mechanism and economic characteristics make it substantially equivalent to a regulated financial instrument whose primary regulatory framework governs continuous-price settlement." (Retain remainder of § 104.) - Add to § 106 a reclassification trigger: "A covered operator shall re-apply the § 104 determination, and an assessor shall re-examine any reliance on § 104(d)(1), whenever a materially relevant change in federal or other applicable law or market practice affecting continuous-price financial instruments occurs; the operator shall document the analysis used to determine equivalence or non-equivalence." What this does to PMCPS-M: PMCPS-M § 202(b) continues to take applicability from PMCPS-C § 104; narrowing § 104(d)(1) reduces the set of products to which PMCPS-M applies (i.e., binary/threshold price contracts remain in scope while continuous-price instruments that are functionally financial remain excluded). Operators relying on the § 104(g)(1) equivalence exclusion must maintain the reclassification record required by PMCPS-C § 105 and the new re-examination documentation under § 106.
• S012: Remove the mandatory external independent-integrity-monitor requirement in PMCPS-M § 405(b) and replace it with a disclosure-plus-assessor-review regime and an evidence-driven sunset/reinstatement clause: - Delete PMCPS-M § 405(b) in its current form. Replace with a new § 405(b) that reads: "A covered operator shall maintain and operate automated surveillance sufficient to detect the conduct prohibited by § 401 and shall publicly disclose, at the point of first order entry and in the persistent disclosures required by § 303, (1) the existence of its surveillance function, (2) the categories of activity it monitors, and (3) the process by which it reports potential misconduct to an assessor and any applicable regulatory authority. The operator shall make surveillance methodology, data retention practices, and sampling results available for confidential review by the assessor required under § 604. Where an assessor or an applicable regulatory authority finds material gaps in the operator's surveillance or reporting, the assessor or authority may require reinstatement of an independent integrity monitor under terms it specifies; the operator shall comply while corrective measures are implemented." When this changes PMCPS-M elsewhere: This substitution preserves PMCPS-M § 405(a) (automated surveillance), § 603 (incident reporting), § 701 (assessor competence), § 602 and § 604 (periodic reporting and audits/assessor review) as the primary verification points. It removes the prescriptive, across-the-board external-monitor mandate and instead ties any external-monitor requirement to demonstrated gaps found in assessor review or regulator action.

3. Vote Phase

Votes on S001: Replace PMCPS-M §208 with the following instructional text and evidence requirements (and where the covered operator is a registered designated contract market (DCM) under the Commodity Exchange Act, substitute the alternative compliance pathway stated below): - PMCPS-M §208 Independent testing - mandatory evidence and DCM alternative (a) For a covered operator that is not a registered DCM: the covered operator shall obtain and retain written certification from an independent testing laboratory that its systems satisfy §207. The independent testing laboratory report shall, at minimum, include: (1) a statement of the laboratory's independence and lack of prior design/implementation role; (2) the scope of testing mapped to each §207 obligation tested (including itemized test cases that demonstrate point-of-entry enforcement of limits and exclusions, rejection-on-failure behavior, timestamp fidelity, activity-history reconstruction, and excluded-participant blocking); (3) test procedures and pass/fail results, including dates, system build version(s) tested, and a list of any test exceptions; (4) evidence of remediation for each exception (remediation plan, remediation completion evidence, and retest results); (5) a vulnerability/penetration test summary and any critical findings with mitigation evidence; and (6) the date of report, signature/attestation by the lead tester, and retention of raw test artifacts for five years. (b) Evidence to be produced to an assessor or applicable regulatory authority: the full testing report required under paragraph (a), the remediation records, and a copy of the independent laboratory's credentials and scope of accreditation. (c) Certification frequency and triggers: certification shall be renewed at least every two years and also upon any material change to the systems under §207(b). Evidence of renewal or of a material-change retest shall be the testing report described in paragraph (a). (d) DCM alternative compliance pathway (replacement text where a covered operator is a registered DCM): a DCM may satisfy paragraphs (a)-(c) by producing, in lieu of a separate independent laboratory report, the contemporaneous testing, attestation, and submissions required by the Commodity Exchange Act and 17 C.F.R. (including system safeguard testing and attestations performed under 17 C.F.R. §§ 38.1050-38.1051, Part 38 system certification/attestation artifacts, and any Part 40 self‑certification materials that include product/system testing). The DCM must produce: (1) the filings made to the Commission (date-stamped copies) and any independent lab reports relied upon in those filings; (2) the internal test plans and post-change test results mapping to PMCPS-M §207 obligations; and (3) remediation evidence and the working papers necessary to verify the testing conclusions. (e) Where there is any divergence between the testing scope required by Part 38 (or other CFTC obligations) and the items mapped to PMCPS-M §207, the covered operator shall supply the additional test artifacts necessary to demonstrate compliance with each PMCPS-M §207 element not covered by the CFTC filings. (f) Retention: all reports and raw test evidence required by this section shall be retained for five years and produced to an assessor or any applicable regulatory authority on request.

Result: 5 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED

Votes on S002: Amend PMCPS-M §405 and add a new paragraph specifying minimum documentary evidence of surveillance and independent integrity monitoring; and add a narrow DCM-specific reporting alignment clause. Replace current §405(b) with the following text: - PMCPS-M §405 Surveillance and independent integrity monitoring - evidence and DCM alignment (a) Surveillance program evidence. A covered operator shall maintain a documented automated surveillance program sufficient to detect the prohibited conduct in §401. For each surveillance rule or analytic used the operator shall retain and produce on request: (1) the written surveillance policy and rulebook (including rule purpose and detection logic); (2) the historical threshold/configuration values and change log (who changed, when, and why); (3) alert logs showing each triggered alert, time-stamped analyst notes, inquiries opened, and final disposition; (4) a sample of surveillance output demonstrating detection of at least one true positive and one false positive, with corresponding remediation or tuning records; and (5) weekly and monthly exception reports for the prior twelve months, and metrics on mean time to detect and mean time to respond. (b) Independent integrity monitor - contract and product evidence. The covered operator shall contract with an independent integrity monitor and shall retain and produce: (1) the contract or engagement letter specifying independence, scope, deliverables, reporting cadence, confidentiality protections, and escalation paths (including obligations to report to applicable authorities); (2) the monitor's written methodology for trade and conduct surveillance and data access to trading and resolution artifacts; (3) copies of all integrity-monitor reports issued during the prior twelve months (redactions permitted only for personally identifying information where required by law), and evidence that the covered operator acted on corrective recommendations (remediation plans and completion evidence); (4) the monitor's personnel qualifications and documented training program; and (5) records of information-sharing with other monitors where relevant to cross-platform conduct. (c) DCM alignment and Commission reporting. Where the covered operator is a registered DCM: (1) the operator may satisfy paragraphs (a)-(b) by producing the surveillance program, surveillance logs, monitoring reports, and any materials sent or required to be made available to the Commission under 17 C.F.R. Part 38 and related directives (including evidence supporting continuous/24/7 monitoring and staffing per CFTC Staff Advisory 26-16); (2) if a DCM's rules or monitoring activity are the subject of a Commission stay or directive (for example as in CFTC Press Release 9267-26), the covered operator shall contemporaneously produce the Commission directive and evidence of compliance with it to the assessor together with the surveillance records required herein. (d) Confidentiality. Integrity monitoring reports and surveillance logs are confidential but shall be produced to an assessor and to any applicable regulatory authority on request; the operator shall document the legal basis for any redactions.

Result: 3 YES / 2 NO / 1 ABSTAIN → 60% (threshold: 51%) → PASSED

Votes on S003: Amend PMCPS-M § 301(d) and related recordkeeping paragraphs to require both immediate allowance of risk‑reducing exit orders for an excluded participant and a one‑time, optional participant‑initiated liquidation offer at a transparent reference price. Insert the following text as new subparagraphs to § 301(d) and add recordkeeping obligations to § 601: - New § 301(d)(5): "In addition to permitting risk‑reducing orders, a covered operator shall offer each newly enrolled excluded participant, at enrollment and for thirty calendar days thereafter, a one‑time optional liquidation transaction that, if elected by the participant, will attempt to close the participant's open positions at a firm reference price. The operator shall present the option in the same enrollment flow that confirms exclusion and shall not require additional customer service contact." - New § 301(d)(6): "The reference price for the optional liquidation shall be the mid‑market price (the arithmetic mean of the best bid and best ask) displayed in the covered operator's continuous order book at the time the participant elects the liquidation, unless the participant elects a time‑weighted average price (TWAP) over a period of not less than five minutes. The operator shall execute the liquidation as a single marketable order against live liquidity and shall not impose a fee, charge, or penalty on the liquidation proceeds. If the order is not marketable within sixty seconds the operator shall cancel the offered liquidation and notify the participant; the participant retains the right to place risk‑reducing orders under § 301(d)(1)." - New § 301(d)(7): "The operator shall include conspicuous pre‑election disclosure of (i) the mechanics of the optional liquidation, (ii) the reference‑price method to be used, (iii) the risk that the reference price may differ from prices realized in the market, and (iv) that acceptance of the optional liquidation is binding." - Amend § 601(a) to add new record items retained for not less than five years: "(10) a record of the offer of the one‑time optional liquidation, whether it was accepted or declined, the reference price quoted, execution records if accepted, and notifications sent; (11) logs demonstrating that risk‑reducing orders by an excluded participant were accepted and executed, including timestamps and execution receipts." Apply consequential edits to PMCPS-C §105(d)/(e) only to reference retention and production obligations already required in PMCPS-M §601 for these records.

Result: 3 YES / 0 NO / 3 ABSTAIN → 100% (threshold: 51%) → PASSED

Votes on S004: Require pre‑listing filing of classification determinations and expand mandatory reporting and retention of exclusion/problem‑gambling metrics to match current state operator practice (Nevada, New Jersey, Ohio). Implement the following edits: 1. Amend PMCPS-C §105: - Replace § 105(a)-(e) with text requiring that, for any product the covered operator intends to offer to participants located in a jurisdiction that has adopted these Standards or to participants resident in a jurisdiction where the operator relies on a gaming licence equivalence under § 104(g)(1), the covered operator must file the written classification determination required by § 105 with the applicable regulatory authority and with its assessor at least fourteen calendar days before the product is first offered in that jurisdiction. The filing must include all items listed in § 105(b) and any material supporting documentation. The operator must update the filing within seven calendar days of any reclassification event under § 106. - Retain the five‑year retention obligation but add that the filing copy must be retained and made available to any adopting regulatory authority for not less than five years after the product is last offered. 2. Amend PMCPS-M § 304 (problem gambling plan) and § 303(a)(8), and expand § 602 reporting and § 601 records: - New PMCPS-M § 304(a)(10): "The problem gambling plan shall designate an RG (Responsible Gaming) Lead with contact information, specify data‑driven 'RG triggers' (for example: cumulative deposits, turnover thresholds, frequency of withdrawals/reversals, frequency of login/session duration, and repeated self‑exclusion page access), and document the phased interventions to be applied when a trigger is met." - New PMCPS-M § 304(b) (expanded reporting): "A covered operator shall submit quarterly to its assessor and to any applicable regulatory authority: (i) the number of participants identified by each RG trigger and the remediation steps taken; (ii) the number of 'at‑risk' patrons added to an operator list, the basis for that determination, and the number not deemed at‑risk together with a written explanation retained for five years; and (iii) confirmation that marketing suppression and account restrictions were applied within fifteen calendar days of exclusion enrollment." - Amend PMCPS-M § 303(a)(8) to require that problem‑gambling help resources include, where required by the adopting authority, the helpline number designated by that authority and that the operator shall update the number within seven calendar days of any regulatory notice (e.g., Nevada Gaming Control Board Notice 2025‑74). - Expand PMCPS-M § 602(a) to add quarterly reporting items: "(7) number of participants flagged by RG triggers, actions taken, and number of participants for whom the operator declined to designate 'at‑risk' with the operator's five‑year retained explanation; (8) the number and timing of marketing suppression actions and evidence of suppression (suppression logs); (9) the number of exclusion enrollments by term and the number of orders and deposit attempts blocked, plus the number and type of exit/closing orders executed by excluded participants (including one‑time liquidations under §301)." - Amend PMCPS-M § 601(a)(3) and (9) to specify retention of marketing suppression logs, the RG trigger event logs, and five‑year retained explanations when a flagged patron is not designated at‑risk.

Result: 3 YES / 2 NO / 1 ABSTAIN → 60% (threshold: 51%) → PASSED

Votes on S005: Amend PMCPS-M §207(a)(2) and add transitional and implementation paragraphs to recognise realistic market structure and to define the least‑cost, verifiable means a running platform may use to meet the "point of order entry" enforcement requirement. Replace §207(a)(2) with the following text and add new paragraphs (a)(2)(A)-(D): (2) enforce every limit, exclusion, and restriction required by these Standards at the point of acceptance of an order into the covered operator's authoritative order book ("order acceptance"), and not rely solely on post‑hoc review. Where the covered operator's technology or market structure results in an upstream order‑submission path (including third‑party gateways, sponsored access, or pre‑validated order feeds) such that enforcement may occur upstream of the covered operator's order acceptance, the covered operator shall satisfy paragraph (a)(2) by one of the following verifiable means: (A) Direct enforcement at order acceptance: the covered operator's venue enforces the control prior to accepting the order into its authoritative order book, rejecting non‑compliant orders in real time with a rejection code indicating the control triggered. (B) Upstream assertion with verifiable acceptance token: the covered operator accepts pre‑validated orders only where the submitting party supplies a cryptographically verifiable enforcement assertion token (opaque to participants) that demonstrates, at the time of submission, that the order passed the controlling check(s). The covered operator shall verify the token before order acceptance, log the verification result, and reject the order if verification fails. (C) Where (B) is used, the covered operator shall retain, and make available to an assessor on request, an auditable record tying each accepted order to the enforcement assertion (including timestamped assertion token, verifying metadata, and rejection reason codes for attempted orders that failed verification). (D) For running platforms only: where implementation of (A) or (B) requires modification of third‑party gateways, network paths, or client software, the covered operator may adopt documented compensating controls for up to six months from the effective date of this Standard, provided the operator (i) contemporaneously logs every pre‑accepted order, attempted order rejection, and the outcome of any upstream checks, (ii) submits a migration plan to the assessor within thirty days showing how it will implement (A) or (B), and (iii) implements (A) or (B) no later than six months after the effective date. During the transition, the system shall continue to "fail safe" by rejecting orders where a required control is unavailable. Add to §207(a) a new advisory sentence: "As drafted, the requirement in paragraph (a)(2) cannot be satisfied by a venue that merely relies on opaque upstream broker checks without the verifiable linkage and real‑time rejection behaviour described above; assessing compliance requires the artifacts specified in (a)(2)(B)-(C)."

Result: 5 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED

Votes on S006: Amend PMCPS-M §501 and §502 to require a machine‑readable, versioned, and immutably recorded "resolution specification" for every covered contract; clarify the conditions under which an operator may act as the resolution source, and provide the minimal procedural and technical steps that permit listing where no independent source exists. Insert before PMCPS-M §501(a) a new definition in §203(b): "Resolution specification" means a machine‑readable, versioned data object (e.g., JSON) published at contract listing that (i) encodes the precise condition that determines settlement (including any thresholds, normalization, filters, and tie‑breaking rules), (ii) identifies the resolution source(s) by unique identifier and access method (URL, API endpoint, dataset identifier), (iii) states the exact UTC timestamp at which the resolution source will be consulted, and (iv) records fallback procedures if the primary source is unavailable or ambiguous. The resolution specification shall be content‑addressed and its cryptographic hash recorded in the contract's immutable listing record. Replace PMCPS‑M §501(a) and add a new §501(d) as follows (edits shown as replacement & addition): (a) A covered operator shall, before listing a covered contract and continuously thereafter, publish for that contract a resolution specification satisfying the definition in §203(b), including: (1) the precise condition that determines settlement, expressed in the resolution specification so that outcome can be determined by applying the specification to the identified resolution source without discretionary interpretation by the covered operator where feasible; (2) the resolution source identified specifically and by unique identifier suitable for machine access; (3) the exact time (in UTC) at which the resolution source will be consulted; (4) the treatment of the contract if the resolution source does not publish, publishes ambiguously, or ceases to exist, encoded as a deterministic fallback algorithm where feasible; (5) the treatment of the contract if the underlying event is cancelled, postponed beyond a stated date, or materially altered; and (6) the treatment of the contract if the resolution source revises its determination after settlement. (d) A covered operator shall refuse to list a covered contract unless the resolution specification either (i) encodes an unambiguous, machine‑executable determination rule that can be applied to the identified resolution source(s), or (ii) where an unambiguous machine rule is not feasible, the operator designates in the specification a pre‑identified independent adjudicator or panel and an unambiguous review standard and publishes the adjudicator's commitment to be bound by that standard. Where the operator is itself the designated adjudicator under (ii), the operator must disclose that fact at point of order entry, and the determination shall be subject to post‑settlement independent review under §504 by a person independent of the operator. Amend PMCPS‑M §502(c) to require machine publication and retention: (c) Where no independent resolution source exists for an event, a covered operator may determine the outcome only if it (1) discloses in the resolution specification that it is the resolution source, prominently and at the point of order entry; (2) publishes in the resolution specification the evidence it will consider and the review standard it will apply; (3) publishes its determination with the reasoning and the evidence relied on; (4) records the evidence and reasoning in an append‑only, timestamped record and submits determinations under this paragraph to review under §504. Add to PMCPS‑M §505(a) a new requirement to attach the resolution specification hash to the contract review documentation retained under §601. Transitional provision: A covered operator shall implement machine‑readable resolution specifications for all newly listed contracts on or before six months after the effective date of this Standard and shall convert existing listed contracts' resolution criteria to resolution specifications within nine months. During conversion the operator shall publish a human‑readable resolution statement and the interim mapping to the machine specification; after nine months, listings without a resolution specification shall be delisted.

Result: 4 YES / 1 NO / 1 ABSTAIN → 80% (threshold: 51%) → PASSED

Votes on S007: Amend PMCPS-M § 501 and related system/settlement provisions as follows: - Add to § 501(a) a new paragraph (7) requiring that the operator present the following facts to the participant at the point of order entry (i.e., on the order-entry screen before the participant submits the order) and in the order confirmation message: - the precise, machine-identifiable resolution source (name and URL or unique identifier); - the single-sentence plain‑language settlement condition derived from § 501(a)(1) that will be applied to that source; - the exact time or deadline when the resolution source will be consulted (§ 501(a)(3)); - whether the resolution source is independent of the operator or is the operator/affiliate or a person compensated by the operator; - whether that resolution source (or the contract type) is under a known regulatory review or subject to a group prohibition or stay. - Add to § 501(c) (amendment prohibition) a sentence: “An operator shall not change the resolution source after a participant has submitted an order for that contract, except to correct a manifest error under § 503(b). If the operator changes the resolution source after orders are executed, the operator must (i) notify affected participants within 24 hours and (ii) permit affected participants to close or reduce their positions without fee for a period of 48 hours following notice.” - Amend § 504 to specify that a participant may contest a settlement within 14 calendar days of publication of the settlement value; upon filing a contest under § 504(a) the participant may request a provisional administrative hold on contested settlement proceeds pending resolution of the dispute, and the operator shall grant such a hold until the contest is resolved or the hold period expires pursuant to the operator’s published procedure. Apply corresponding edits to PMCPS-C § 105(b)(3) to require that the classification record identify the precise resolution source in the form required by the new § 501(a)(7), so the classification record and participant disclosure use identical identifiers.

Result: 3 YES / 2 NO / 1 ABSTAIN → 60% (threshold: 51%) → PASSED

Votes on S008: Amend PMCPS-M § 301, § 302, and § 403 to require specific, timed participant-facing controls and facts at registration, at first deposit, on first order entry, and on login when location changes: - Add to § 301(a) and § 302(c) that at (1) account registration, (2) the first deposit, and (3) on the order-entry screen before the participant submits a first order in any covered contract, the operator must present a non-dismissable modal that states, as facts: - the participant’s verified minimum‑age status (pass/fail) and the minimum age applied; - whether the participant’s current jurisdiction permits the participant to trade the specific covered contract(s) offered (Yes/No). If No, the modal must state that trading is blocked and provide the actions the participant may take (close positions, cancel resting orders, withdraw funds) and the means to do so. - a concise list of available self‑exclusion terms (one year, five years, lifetime) and direct one‑click controls to enroll immediately without contacting customer service; - the three limit types (deposit, spend, loss) and session time limit with one‑click controls to set each immediately (durations 24h, 7d, 1 month) and a one‑click 72‑hour suspension option. - Amend § 302(c) to require the operator to enforce these modal controls so that a participant may not submit their first order in a covered contract until they have either (i) set limits or self‑exclusion via the modal, or (ii) affirmatively chosen “proceed without setting limits” by checking a box acknowledging the risk of total loss (this acknowledgement must be recorded). - Add to § 403(c) that when the participant’s detected location indicates a jurisdiction where the operator is not authorized to offer the specific covered contract, the operator shall present the same modal at login and shall block order entry for that contract type; the operator shall not route, proxy, or otherwise attempt to permit trading from that location by routing through affiliates or third parties.

Result: 3 YES / 0 NO / 3 ABSTAIN → 100% (threshold: 51%) → PASSED

Votes on S009: Amend PMCPS-M § 402 by adding a new subsection (g): "A covered operator shall log each instance in which an individual is matched against, added to, or blocked by the restricted list maintained under subsection (e), recording the date, the covered contract concerned, and the action taken. This log shall be retained under § 601(a) and produced on request to an assessor or applicable regulatory authority." Correspondingly amend § 601(a)(5) to read "documentation under § 402(c), the screening log under § 402(g), and § 505(a) for each covered contract listed."

Result: 5 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED

Votes on S010: Amend PMCPS-M § 503 to add a distinct correction ground for resolution-source revision, separate from manifest error. Insert new § 503(b-1): "A covered operator may also correct a settlement where the resolution source itself revises the factual determination on which the settlement relied, provided the correction is made within the period published under § 501(a)(6), is published with the source's revised determination and the operator's basis for reliance on it, and is reported under § 603." Amend § 503(c) to read: "...where the published criteria were correctly applied to the resolution source's determination as it stood at settlement, and no revision under paragraph (b-1) has occurred."

Result: 5 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED

Votes on S011: Amend PMCPS-C § 104(d)(1) and PMCPS-C § 106 to narrow the commodity/index carve-out and add an explicit review trigger: - Replace current § 104(d)(1) with: "A product whose payout is the continuous, point-in-time price, rate, level, or index value of a commodity, security, or index (i.e., the contract settles at the underlying level rather than by reference to a discrete threshold or occurrence) is excluded from this Standard; binary, threshold, or otherwise discretized contracts that pay on whether an underlying price, rate, or index crosses a stated threshold remain subject to the test in § 104. The exclusion applies only where the contract's settlement mechanism and economic characteristics make it substantially equivalent to a regulated financial instrument whose primary regulatory framework governs continuous-price settlement." (Retain remainder of § 104.) - Add to § 106 a reclassification trigger: "A covered operator shall re-apply the § 104 determination, and an assessor shall re-examine any reliance on § 104(d)(1), whenever a materially relevant change in federal or other applicable law or market practice affecting continuous-price financial instruments occurs; the operator shall document the analysis used to determine equivalence or non-equivalence." What this does to PMCPS-M: PMCPS-M § 202(b) continues to take applicability from PMCPS-C § 104; narrowing § 104(d)(1) reduces the set of products to which PMCPS-M applies (i.e., binary/threshold price contracts remain in scope while continuous-price instruments that are functionally financial remain excluded). Operators relying on the § 104(g)(1) equivalence exclusion must maintain the reclassification record required by PMCPS-C § 105 and the new re-examination documentation under § 106.

Result: 5 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED

Votes on S012: Remove the mandatory external independent-integrity-monitor requirement in PMCPS-M § 405(b) and replace it with a disclosure-plus-assessor-review regime and an evidence-driven sunset/reinstatement clause: - Delete PMCPS-M § 405(b) in its current form. Replace with a new § 405(b) that reads: "A covered operator shall maintain and operate automated surveillance sufficient to detect the conduct prohibited by § 401 and shall publicly disclose, at the point of first order entry and in the persistent disclosures required by § 303, (1) the existence of its surveillance function, (2) the categories of activity it monitors, and (3) the process by which it reports potential misconduct to an assessor and any applicable regulatory authority. The operator shall make surveillance methodology, data retention practices, and sampling results available for confidential review by the assessor required under § 604. Where an assessor or an applicable regulatory authority finds material gaps in the operator's surveillance or reporting, the assessor or authority may require reinstatement of an independent integrity monitor under terms it specifies; the operator shall comply while corrective measures are implemented." When this changes PMCPS-M elsewhere: This substitution preserves PMCPS-M § 405(a) (automated surveillance), § 603 (incident reporting), § 701 (assessor competence), § 602 and § 604 (periodic reporting and audits/assessor review) as the primary verification points. It removes the prescriptive, across-the-board external-monitor mandate and instead ties any external-monitor requirement to demonstrated gaps found in assessor review or regulator action.

Result: 0 YES / 5 NO / 1 ABSTAIN → 0% (threshold: 51%) → FAILED

4. Pass List

Total: 12 suggestions reviewed. 11 passed. 1 failed.

S001 key rationales: - The State Gaming Regulator: This makes the independent-testing obligation auditable and harmonizes with CFTC‑regulated DCM evidence so assessors can verify technical compliance without duplicative testing; note for assessors that where a state gaming rule inspired a test artifact requirement, it must be adapted to record the transferability of positions (e.g., include proof that tests cover order-book metadata and transfer/assignment workflows that do not exist in fixed‑odds systems). - The Exchange Operator: Specifies the concrete test artifacts and retention an assessor needs, creating verifiable evidence with modest laboratory/reporting costs and minimal transition burden (cheapest compliant route: an independent lab report containing the enumerated items and five‑year raw‑artifact retention). - The Participant Advocate: Requiring a specific, test‑artifact evidence set (scope mapping, pass/fail results, remediation, raw artifacts, and lab credentials) gives assessors the concrete records they need to verify that participant protections in §207 are actually implemented and avoids needless duplicate testing for DCMs. - The Settlement and Integrity Specialist: The added test-scope, artifact, and remediation-evidence list closes the "obligation without evidence" gap in §208, and the DCM alternative properly cites primary CFR provisions rather than resting on a search result. - The Minimal Intervention Advocate: Replaces a vague independent-testing obligation with a concrete, verifiable artifact set and a sensible DCM alignment that reduces assessor discretion and avoids duplicative testing.

S002 key rationales: - The State Gaming Regulator: Clear surveillance and independent‑monitor artifacts are essential for verification and the DCM alignment avoids conflicting federal obligations; where state gaming models assume non‑transferable wagers, the evidence list must be expanded for transferable exchange positions to include logs demonstrating enforcement of exclusion/limit checks at matching and post‑trade transfer events. - The Exchange Operator: Provides the documentary surveillance and monitor artifacts assessors require for verification; it imposes ongoing contract and reporting costs but the DCM alignment clause reduces duplication for registered venues. - The Participant Advocate: Specifying the surveillance rulebook, alert logs, monitor contract, monitor reports, and remediation evidence converts an otherwise‑abstract surveillance obligation into verifiable artifacts and sensibly aligns production with Part 38 obligations for DCMs.

S003 key rationales: - The Derivatives Regulator: It closes a real assessability gap by mandating an auditable, time‑bounded optional liquidation and explicit retention items so an assessor can verify exits occurred; no clear conflict with DCM obligations identified. - The Participant Advocate: Requiring an immediate automated acceptance of risk‑reducing orders plus a one‑time, transparent liquidation offer at a defined reference price gives newly excluded participants a concrete, auditable exit option and creates the retention records assessors need to verify it was offered and executed. - The Settlement and Integrity Specialist: It closes a real operational gap in §301(d) with a concrete, auditable mechanism (reference price, execution window, retention records) and correctly limits its cross-document edit to a retention/production pointer in PMCPS-C §105.

S004 key rationales: - The Exchange Operator: Requiring pre‑listing classification filings and expanded, standardized RG metrics gives regulators and assessors the pre‑offer evidence they need and is implementable by automated pre‑listing submissions and quarterly reporting processes used in several states. - The Participant Advocate: Mandating pre‑listing filing of classification determinations and richer, standardized quarterly RG metrics ensures regulators can intervene before harmful products are offered and creates the documentary trail necessary for assessors to verify classification and RG actions. - The Minimal Intervention Advocate: Requiring pre-listing filings and standardized RG metrics materially improves assessability and regulator oversight and makes classification and remediation verifiable without adding new substantive prohibitions.

S005 key rationales: - The Derivatives Regulator: Provides the concrete, verifiable artifacts assessors need to judge “point of order entry” enforcement and a realistic transition path; for registered DCMs accept that production of Part 38 system‑safeguards testing/attestations and related Part 38/40 filings (17 C.F.R. §§ 38.1050-38.1051 and Part 40 product/rule materials) will satisfy the requirement where those filings cover the same enforcement elements. - The State Gaming Regulator: The token/verification alternative and time‑limited transition produce a practicable, verifiable way to meet the "point of order entry" goal in typical market architectures and create the logs assessors need to confirm enforcement rather than mere intent. - The Participant Advocate: The proposed acceptance/assertion token and logging options (plus a limited transition) reconcile the "point of order entry" requirement with real market architectures while producing the verifiable linkage artifacts assessors need to conclude controls ran when orders affected the book. - The Settlement and Integrity Specialist: It resolves a genuine ambiguity in §207(a)(2) about enforcement point under realistic gateway architectures, defines verifiable artifacts (token, logs), and bounds the transitional period rather than leaving it open-ended. - The Minimal Intervention Advocate: Recognizes real-world market structure and provides the least-cost, verifiable paths (on-venue enforcement or cryptographic assertion + logs) plus a short transitional window, all of which preserve the protection goal while avoiding wholesale re-engineering.

S006 key rationales: - The Derivatives Regulator: Requiring a versioned, machine‑readable resolution specification plus a content‑addressed hash materially improves verifiability and post‑settlement review; for registered DCMs permit the Part 40 product specification and associated settlement rules to be mapped to the machine spec (with the mapping and hash retained) where the Part 40 filing already defines the same settlement mechanics. - The State Gaming Regulator: Requiring a versioned, machine‑readable resolution specification with a content hash supplies an inexpensive, auditable artifact that prevents post‑listing ambiguity and fits the realities of exchange‑style, transferable positions where precise settlement determinism is essential. - The Participant Advocate: Requiring a machine‑readable, versioned resolution specification with an immutable hash at listing makes settlement mechanics auditable and automatable where feasible, and the independent‑adjudicator fallback protects participants where machine determinism is impossible. - The Minimal Intervention Advocate: Machine‑readable, versioned resolution specifications (with content-addressed hashes) produce cheap, auditable artifacts that prevent post‑listing operator discretion and make settlement determinations and assessor review reproducible.

S007 key rationales: - The State Gaming Regulator: Requiring exact, machine‑identifiable resolution‑source disclosure at order entry and a narrow change control with participant remedies protects participants and creates clear evidence for assessors; for transferable positions this is particularly important because the stakes of post‑trade source changes are higher than in fixed‑odds wagers. - The Exchange Operator: Requiring machine‑identifiable resolution‑source disclosure at order entry, an operator change prohibition except for manifest errors, and a 14‑day contest with provisional hold gives participants meaningful pre‑trade facts and a workable post‑settlement remedy; it is enforceable through order‑entry UI/confirmation messages and settlement workflow changes. - The Minimal Intervention Advocate: Requiring point‑of‑order disclosure of the exact resolution source and settlement rule, prohibiting post‑order source changes except for manifest error, and providing a short contest/hold remedy materially improves informed consent and preserves participant funds without unduly intruding on price discovery.

S008 key rationales: - The State Gaming Regulator: Mandating non‑dismissable, one‑click self‑exclusion and limit controls at high‑impact moments gives participants effective, auditable tools to reduce harm and prevents burying protections behind manual processes that are unacceptable for exchangeable positions. - The Exchange Operator: Non‑dismissable, one‑click controls at registration/first deposit/first order and enforced jurisdictional blocks operationalize protections at decisive user moments and are enforceable at point of order entry, though they require UI changes, geolocation enforcement, and migration planning for running platforms. - The Settlement and Integrity Specialist: It specifies concrete, timed, one-click controls and modal disclosures that convert existing but vague §301/§302/§403 prompts into verifiable, evidence-producing obligations without redrafting the whole Part.

S009 key rationales: - The Derivatives Regulator: Adding an auditable screening log is precisely the kind of operational evidence assessors need to verify enforcement of restricted‑list screening; for registered DCMs this can be satisfied by producing the venue’s Part 38 audit/trade surveillance logs where they demonstrably record the same screening events. - The State Gaming Regulator: Adding a screening log requirement fills a current evidence gap by proving the restricted‑list screening actually ran and produced actions, an essential audit trail for verifying performance rather than policy. - The Exchange Operator: Adding a required screening log for the restricted list is the minimal, low‑cost fix to the current evidence gap and produces the direct audit trail assessors need to verify that screening actually occurred. - The Participant Advocate: Adding a mandatory screening log tying each screening event to actions taken fills the current evidentiary gap and gives assessors the records needed to verify the restricted-list screening obligation is actually executed. - The Minimal Intervention Advocate: Adding a screening log for restricted-list matches closes the "obligation without evidence" gap by creating an auditable trail showing that screening and blocking actually occurred and is thus directly assessable.

S010 key rationales: - The Derivatives Regulator: This fills the logical gap between §501(a)(6) and §503 by giving operators a clear, auditable correction path where the resolution source itself revises its determination and aligns the standard with real‑world source behavior. - The State Gaming Regulator: Explicitly permitting corrections when a resolution source revises its determination resolves a real‑world inconsistency between §501(a)(6) and §503 and provides a clear, time‑bounded correction path necessary for fair outcomes in transferable contracts. - The Exchange Operator: Introducing a correction ground for resolution‑source revisions closes the internal inconsistency between §501(a)(6) and §503 and is implementable by a bounded settlement‑amendment procedure with reporting under §603. - The Participant Advocate: Adding a discrete correction ground for a resolution‑source revision resolves the internal contradiction between §501(a)(6) and §503 and gives participants a predictable, published remedy when a source revises its determination. - The Minimal Intervention Advocate: Correctly fills the logical gap between §501(a)(6) and §503 by permitting correction when a resolution source itself revises its determination within a disclosed period, aligning the standard's published policy with an operative correction ground.

S011 key rationales: - The Derivatives Regulator: Narrowing the continuous‑price carve‑out to contracts that are truly economically equivalent to regulated financial instruments (and adding a reclassification trigger) improves legal and assessor certainty and correctly reduces PMCPS‑M’s coverage under PMCPS‑C §104; implementational effect: PMCPS‑M §202(b) will apply to the narrower set identified by the revised §104. - The State Gaming Regulator: Narrowing the continuous‑price carve‑out to economic equivalence and requiring reclassification triggers prevents both under‑ and over‑inclusion and forces operators to document why discrete threshold products remain within PMCPS while continuous financial instruments do not; where state gaming text is referenced, the operator must show how transferability and secondary‑market characteristics alter the risk profile vs. fixed‑odds products. - The Exchange Operator: Narrowing the §104(d)(1) carve‑out to continuous‑price instruments economically equivalent to regulated financial products and adding a reclassification trigger makes scope determinations evidence‑based and auditable, requiring operators to maintain classification/re‑examination records (an administrative but practicable obligation). - The Participant Advocate: Narrowing the continuous‑price carve‑out to contracts that are substantively equivalent to regulated financial instruments, and requiring re‑examination on material legal/market change, prevents misclassification that would strip participant protections while avoiding duplicative regulation of genuine financial instruments. - The Settlement and Integrity Specialist: It narrows an overly categorical carve-out with a functional-equivalence test and adds a reclassification trigger, which reads as a genuine third option (an equivalence-based test) rather than a restatement of either alternative named in Appendix C item 1.

5. Completion

Timestamp: 2026-09-09T15:43:44+00:00 Configured actions: report, publish

• report OK: report present and current at /mnt/d/tools/apps/predmarket-standards/logs/report.md
• publish OK: pass list published to /mnt/d/tools/apps/predmarket-standards/logs/published/latest.json (and pmcps-committee-2026-09-09.json)