PMCPS Standards Committee - Session Minutes

Date: 2026-10-02 Board: pmcps-committee Documents reviewed: PMCPS-C v1.2 Classification Standard | PMCPS-M v1.2 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 v1.2 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 1.2 is the text under review. It adopted the eleven suggestions this board passed on 2026-09-09, applied as twenty-six amendments. By the obligation count defined for this board, obligations rose from 156 to 205, thirty-one percent, and strict-leaf obligation paragraphs from 94 to 113, twenty percent. The only suggestion to remove an existing obligation failed 0 to 5. Read the text as it now stands, including what the last meeting added.

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.

A suggestion that adds an obligation must name the existing obligation it replaces, by section, or state plainly that it replaces none. A board that can only add grows its standard every meeting, and the Sept 9 meeting raised the obligation count by thirty-one percent with no vote on the aggregate.

Your persona limits what you propose. It gives you no ownership of any section. Vote on every suggestion on its merits, including one that touches provisions your persona covers. A vote against a suggestion because another seat proposed it is not a vote on the suggestion.

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 v1.2 and PMCPS-M v1.2. - Requirements that state an obligation without stating what evidence proves it was met. This is the priority for this board. It has two valid answers and they carry equal weight. Either add the evidence requirement that makes the obligation verifiable, or propose removing the obligation, because an obligation that no evidence could show was met may be one that should not exist. A board that only ever gives the first answer ratchets, and that is how the Sept 9 meeting raised the obligation count by thirty-one percent. - The open questions the Institute has flagged as unresolved, being PMCPS-C Appendix C and PMCPS-M Appendix A, twelve items in all. PMCPS-C Appendix C item 1 was narrowed at v1.2 rather than closed. The line is now drawn, and what remains open is whether its substantial-equivalence qualifier is administrable. 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. - On the agenda for this meeting, a contradiction in PMCPS-C. Section 102(a) states that the standard imposes no requirement on the design, operation, or conduct of a covered operator. Sections 105 and 106 impose seventeen obligations on a covered operator, to make, record, file, and redo a classification determination, and the standard carries nineteen in all. The text cannot be applied as published while both statements stand. Resolve it, and say what the resolution does to PMCPS-M, since PMCPS-M section 202(b) takes its applicability from PMCPS-C.

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 every open question 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.

0. Obligation Count

Measured from the documents under review, before this session.

Counting script sha256: 399985abc3376f7df053c1f3955cf10a688ee98d671d5bf71877bdb29a001502

Primary: each shall, must, shall not, must not, may not in operative text, the longest match counted once. Secondary: strict leaf paragraphs containing one. Paragraphs with a term: the same without excluding lead-ins, reported so either reading can be checked.

Recorded judgement calls: - PMCPS-C: Normative although section 102(a) says the standard imposes no requirement on a covered operator's conduct. Sections 105 and 106 impose seventeen such obligations. The contradiction is on the agenda for the meeting of 2026-10-02; until it is resolved the document is counted as what it does, not as what section 102(a) says. - PMCPS-M: Section 202 (Application) is excluded as scope-and-effect under the counting definition, but in v1.2 it carries two real duties, to make and retain a classification determination and to file it where PMCPS-C section 105(d) requires. Counting it would add two obligation terms to the primary figure.

1. Review Phase

Suggestions by Member

The Derivatives Regulator (openai:gpt-5-mini) - S001: Replace PMCPS-C §102(a) with the following text, and add the specified documentary-evidence obligations to PMCPS-C §105(b) as shown. - New PMCPS-C §102(a) (replacement): "This standard determines scope. Except for the procedural recordkeeping and filing obligations set out in §105 and the reclassification obligations in §106, it imposes no operational design, system, or trading conduct requirements on a covered operator. The obligations in §105 and §106 are classification and records obligations and are enforceable as stated." - Amend PMCPS-C §105(b) by inserting at the end of the paragraph the following requirement (to be read as part of §105(b)): "The written determination shall be accompanied by, and the covered operator shall retain and produce on request the following supporting documentary evidence sufficient for an assessor or any applicable regulatory authority to verify the classification: (i) the product specification and full settlement terms relied on for the determination; (ii) the machine‑readable resolution specification required by PMCPS‑M §501(a)(7) and its cryptographic hash; (iii) an evidence map that links each conclusion reached under Gates 1-4 to contemporaneous source documents or records (for example: order‑book snapshots or trade-history extracts showing tradability and market‑determined prices under Gate 3; screenshots or product rules showing whether operator quotes are unilateral under Gate 3; participant account records or declarations relied on to establish a hedging nexus under Gate 4); (iv) where an equivalence exclusion under §104(g)(1) is claimed, a copy of the licence relied on and the operator's documented equivalence analysis and supporting materials; (v) the participant‑facing disclosure materials or screen mockups shown to participants at order entry for the product, including the resolution‑source identifier used at order entry; and (vi) documentary evidence of the identity and authority of the signatory required by §105(c) and proof of the signatory's designation under PMCPS‑M §204(a). These supporting materials shall be retained for the period stated in §105(f) and produced to an assessor or any applicable regulatory authority on request." Rationale: PMCPS‑C currently contains an irreconcilable statement (§102(a)) that the classification standard "imposes no requirement on the design, operation, or conduct of a covered operator" while §105 and §106 impose enforceable, assessable obligations to make, sign, file, retain, and update classification determinations. That contradiction prevents assessors or adopting authorities from applying the standard as published. Further, §105 requires a written determination but does not state what documentary evidence proves compliance - leaving assessors without objective artifacts to verify the determination. The proposed changes (1) resolve the internal contradiction by carving out and preserving the classification/records obligations, and (2) make §105 verifiable by listing the minimum evidentiary artifacts an assessor or regulator may request. Evidence: PMCPS‑C §102(a) (contradictory statement); PMCPS‑C §105 (writes the determination requirement but omits evidentiary detail). The board agenda explicitly identified this contradiction and required resolution (meeting instructions: "On the agenda for this meeting, a contradiction in PMCPS‑C. Section 102(a) states... Resolve it, and say what the resolution does to PMCPS‑M, since PMCPS‑M section 202(b) takes its applicability from PMCPS‑C."). PMCPS‑M §202(b) references PMCPS‑C §105 filings; the added documentary list cross‑links to PMCPS‑M §501(a)(7) resolution‑specification language. What this does to PMCPS‑M: No substantive change to PMCPS‑M is required; PMCPS‑M §202(b) remains the mechanism by which PMCPS‑M applies once a product is classified. The new evidentiary list intentionally references PMCPS‑M §501(a)(7) to ensure internal consistency between documents. If previously proposed similar suggestion was rejected: none previously proposed by me that was rejected on this exact point. (The Sept 9 meeting increased obligations but left this contradiction unresolved; this suggestion addresses that outstanding agenda item.) - S002: Replace PMCPS‑M §208(d) (the Alternative pathway for a registered designated contract market) with the following text to align explicitly with the Commodity Exchange Act and 17 C.F.R. Parts 38 and 40, and to define the evidence a DCM must produce for assessors: - New PMCPS‑M §208(d) (replacement): "Alternative pathway for a registered designated contract market. Where the covered operator is a registered designated contract market (DCM) under the Commodity Exchange Act, the DCM may satisfy paragraphs (a)-(c) by producing, in lieu of a separate independent laboratory certification, the contemporaneous filings, attestations, testing artifacts, and independent reports the DCM is required to generate or files voluntarily under the Commodity Exchange Act and 17 C.F.R. Parts 38 and 40, subject to the following requirements: (1) The DCM shall produce date‑stamped copies of all filings and attestations submitted to the Commission that relate to system safeguards, system testing, product self‑certification, or other testing of systems that map to PMCPS‑M §207 (including but not limited to attestations and testing performed under 17 C.F.R. §§38.1050-38.1051 and any Part 40 self‑certification submissions). (2) The DCM shall produce any independent laboratory reports relied upon in those filings, and the laboratory credentials and scope of accreditation for those reports. (3) The DCM shall produce an explicit mapping (a matrix) that ties each CFTC filing, testing artifact, attestation, and independent report to the specific PMCPS‑M §207 obligation(s) it covers, including the test cases, system build version, and dates of testing. (4) Where any PMCPS‑M §207 element is not demonstrably covered in the Part 38/40 filings and artifacts, the DCM shall produce the additional test artifacts, remediation records, and retest evidence necessary to demonstrate compliance with that PMCPS‑M §207 element. (5) Where the Commission or its staff has issued a directive, stay, or advisory that affects the DCM's testing, monitoring, or listing practices (for example CFTC Staff Advisories regarding continuous monitoring, system safeguards, or product self‑certification), the DCM shall produce the directive or advisory and demonstrable evidence of contemporaneous compliance with it. (6) All materials produced under this paragraph shall be retained for five years and produced to an assessor or any applicable regulatory authority on request." Rationale: PMCPS‑M §208 already contemplates an alternative pathway for registered DCMs, but the operative text should explicitly identify the CFTC regulatory obligations it aligns with and the documentary evidence an assessor may rely upon. DCMs already carry mandatory system safeguards testing and attestations under 17 C.F.R. §§38.1050-38.1051 and must make Part 40 product self‑certifications where applicable. Left unspecified, the alternative pathway risks either (a) creating a duplication of requirements that conflicts with how DCMs document compliance to the Commission or (b) leaving assessors without the mapping required to verify that CFTC filings in fact satisfy PMCPS‑M §207 elements. The replacement text makes clear what DCM submissions constitute acceptable evidence, requires a mapping matrix so assessors can verify coverage of PMCPS‑M §207, and requires DCMs to fill any gaps. Evidence: PMCPS‑M §208 (current alternative pathway); 17 C.F.R. §§38.1050-38.1051 (system safeguard testing/attestation obligations); Part 40 self‑certification obligations (17 C.F.R. §40.2 et seq.). CFTC Staff Advisories 26‑16 and 26‑22 (cited in this file's history and external intel) show the Commission staff's operational expectations for continuous monitoring and product self‑certifications. The board previously passed a closely similar alternative (session S001); this suggestion refines that pathway to name the specific Part 38/Part 40 authorities and to require an explicit mapping matrix. If previously proposed similar suggestion was rejected: A similar text (S001) was passed by the committee (see history S001). No rejection to acknowledge. This suggestion narrows and clarifies the accepted alternative so assessors may objectively verify that CFTC filings cover PMCPS‑M §207 elements. - S003: Remove: PMCPS-M § 304(d): "A covered operator shall contribute to the funding of problem gambling research, prevention, and treatment. The contribution shall be calculated as a stated percentage of gross gaming revenue or an equivalent measure, shall be disclosed publicly, and shall be paid to an entity independent of the covered operator." Rationale: This obligation imposes a quasi‑tax/levy on operator revenue and allocates public‑policy funding responsibility to private market operators. For an operator that is a registered designated contract market (DCM) under the Commodity Exchange Act, this duty collides with the Commission’s existing financial and reporting framework and with the limits on imposing industry‑wide levies outside statutory authority. It is also not administrable uniformly across jurisdictions (national, state, tribal) where funding mechanisms, tax rules, and authorized recipients differ. The provision therefore creates legal and compliance conflicts for DCMs and cannot be verified by evidence that would be consistent across adopting authorities. The standard is better without a mandatory contribution; if an adopting authority wishes to require funding, that should be done by statute or by the adopting regulator, not as a minimum internal control imposed on every covered operator.

The State Gaming Regulator (claude:claude-haiku-4-5) - S004: Amend PMCPS-M § 602(a) to add a new reporting item (10): "the number of participants whose accounts were flagged by RG triggers under § 304(a)(10) but for whom the operator declined to designate 'at-risk' status, together with the five-year retained written explanation for each such declination, aggregated by trigger type and by explanation category." Amend PMCPS-M § 601(a)(9) to specify that the operator shall retain "the RG trigger event logs, the at-risk designation records, and the five-year retained explanations for each declination to designate at-risk status" as part of the problem gambling plan documentation. Rationale: PMCPS-M § 304(b)(2) requires quarterly reporting of "the number identified by a trigger but not designated at risk and a written explanation for each, retained for five years," but the current text of § 602(a) does not list this as a quarterly reporting item, and § 601(a)(9) does not explicitly require retention of the declination explanations themselves. This creates an ambiguity: an operator could retain explanations under § 304(b)(2) without reporting the aggregate count and category of declinations, leaving an assessor or regulator unable to verify whether the explanations exist, whether they are substantive, or whether the operator is applying the at-risk designation consistently. This mirrors the gap identified in the Sept 9 session (S004) where the board found that obligations without stated evidence cannot be assessed. The state gaming frameworks imported in S004 (Ohio, New Jersey, Nevada) all require documented justification for decisions to exclude or restrict a flagged participant; the PMCPS-M text must make that documentation verifiable in the quarterly report. Evidence: PMCPS-M § 304(b)(2) states the obligation to retain explanations "for five years" but does not require them to be reported. PMCPS-M § 602(a) lists nine reporting items, none of which explicitly covers the declination count or explanation category. The Sept 9 session (S004) added § 304(b) reporting and § 601 retention, but left the bridge between retention and reporting incomplete. The New Jersey proposal (PRN 2025-120, cited in external intel) requires "specific data-driven 'RG triggers'" and retention of "explanations when a flagged patron is not deemed at-risk"; this standard imports the trigger mechanism but does not yet import the reporting requirement that makes those explanations auditable. PMCPS-M § 702(b) requires assessment based on "examination of evidence," which cannot occur if the evidence (the declination explanations) is retained but not reported. - S005: Amend PMCPS-M § 501(a)(7) to require that the facts presented to the participant on the order-entry screen include: "(8) whether the resolution source has a documented track record of timely, unambiguous publication of determinations for at least twelve months prior to listing, and if not, the reasons the covered operator believes the source will perform reliably; and (9) the covered operator's policy for settlement correction under § 503(b) and (b-1), including the period within which a correction may be made and the procedure by which a participant may contest a settlement under § 504." Amend PMCPS-M § 505(a) to add a new item (7): "the covered operator has reviewed the resolution source's publication history, where available, and has documented its assessment that the source is capable of publishing determinations in accordance with the resolution specification." Rationale: PMCPS-M § 501 and § 502 require that a resolution source be independent and that the resolution specification be unambiguous, but they do not require the covered operator to verify that the source has demonstrated the ability to publish determinations on time and in the form specified. The external intel today includes a CFTC Enforcement Division advisory (Feb 25, 2026) stating that exchanges must maintain audit trails and conduct surveillance-implicitly, to reconstruct what happened. PMCPS-M § 501(a)(3) requires the operator to state the time at which the resolution source will be consulted, but there is no requirement that the source has ever published on schedule, or that the operator has verified it will. A resolution source that is independent but unreliable (slow, ambiguous, or non-responsive) creates a settlement delay that harms participants by extending their exposure and the operator's settlement obligation. This is distinct from the manifest-error correction in § 503(b), which addresses operator mistakes; it addresses source failure. Participants deserve to know whether the source they are relying on has a track record. The operator deserves to document that it performed due diligence before listing. An assessor under § 702(b) needs evidence that the operator examined the source's actual behavior, not merely its stated independence. Evidence: PMCPS-M § 501(a) requires publication of the resolution source "by name and unique identifier" and "whether the resolution source is independent," but does not require disclosure of the source's publication history or performance record. PMCPS-M § 502(a) requires independence; § 502(c) permits operator determination only where "no independent resolution source exists," but does not require the operator to have searched for one or to have verified that a claimed independent source actually publishes. The CFTC advisory (Feb 25, 2026) cites the duty to maintain audit trails sufficient to reconstruct trading-which presupposes that settlement is reconstructible, i.e., that the resolution source's determination is documented. PMCPS-M § 505(a) requires documentation that "the outcome is verifiable" and "is generated by a process independent of the covered operator," but does not require verification that the process has ever actually generated an outcome on schedule. Ohio Admin. Code 3775-10-01 (cited in the Basis to § 501) requires that gaming outcomes be "verifiable"; a source with no track record is not verifiable in practice. The open question in PMCPS-C Appendix C item 1 (whether the substantial-equivalence qualifier in § 104(d)(1) is administrable) is analogous: it asks whether an operator can apply a standard without clear evidence. This suggestion supplies the evidence standard. - S006: Remove: PMCPS-M § 301(d)(1), the one-time optional liquidation offer > "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 which, if elected, will attempt to close the participant's open positions at a firm reference price." Rationale: As a state gaming regulator, I have implemented exclusion programs in Ohio and other jurisdictions. The obligation to offer a liquidation at a reference price creates three regulatory problems: 1. Operational ambiguity in a market context. In fixed-odds wagering, a position cannot be sold; exclusion simply preserves the right to be paid. A transferable position creates a new harm: the excluded participant bears continuing market risk. But the drafting note acknowledges this is unresolved (Appendix A item 1). Mandating a liquidation offer before that question is settled locks the standard into a solution that may not be correct. 2. Perverse incentive. An excluded participant who declines the liquidation offer and then suffers a loss may argue that the operator failed to adequately present the option, creating dispute and litigation. An operator facing that exposure will over-offer, and an excluded participant facing pressure to decide in thirty days may accept a reference price worse than they could obtain through risk-reducing orders. The supposed protection becomes a trap. 3. Gaps in the requirement itself. The obligation does not specify what happens if the participant declines, what happens if the reference price moves materially between calculation and execution, or what happens if the market is illiquid. These are not details; they are the content of the obligation. An obligation stated without these details cannot be assessed. Alternative: Keep § 301(d) as drafted, but strike § 301(d)(1) and (d)(2). Retain only § 301(d) as the principle-"An excluded participant retains the right to receive any amount owed on a position"-and § 301(d)(2) as the mechanism-"permit an order that closes or reduces an open position." This gives the excluded participant the right to exit at market prices they choose, which is what exclusion requires. The operator's duty is to enforce that right, not to engineer a price.

The Exchange Operator (openai:gpt-5-mini) - S007: Amend PMCPS-C §102(a) to remove the textual contradiction and make explicit which classification obligations are operational. Replace the current §102(a) with the following text (strike/insert as needed): "(a) This standard determines scope. It does not impose technical system design requirements or behavioural obligations on systems that are the subject of PMCPS-T. Notwithstanding that general principle, this standard does impose documentary and filing obligations on a person who offers a product that the standard reaches: the written classification determination, the signature requirement, the filing-before-first-offer obligation, the update and retention duties described in PMCPS‑C §105 and the reclassification and review obligations in §106. Those documentary obligations are operational requirements for the persons who make, file, retain, and produce classification determinations and are enforceable by examination of the records they must retain under PMCPS‑M §601. For clarity, PMCPS‑M §202(b)'s statement that applicability is taken from PMCPS‑C §104 and §105 remains operative and is not changed by this paragraph." Amend PMCPS‑M §202(b) by adding one clarifying sentence at the end: "For avoidance of doubt, the documentary and filing obligations in PMCPS‑C §105 and the reclassification obligations in §106 are operative obligations for a covered operator for the purposes of applicability under this section." Rationale: Resolve the internal contradiction flagged on the meeting agenda: PMCPS‑C currently says it "imposes no requirement on the design, operation, or conduct of a covered operator" while §105 and §106 impose explicit documentary and filing obligations on a covered operator. The contradiction makes PMCPS‑C and PMCPS‑M inapplicable as published because PMCPS‑M §202(b) depends on PMCPS‑C §104 and §105. Making the limited carve-out explicit (no technical system/behaviour requirements in classification; documentary/filing obligations do apply) removes ambiguity so an operator can implement, an assessor can verify by records, and a regulator can adopt by reference. Evidence: PMCPS‑C §102(a) (current text) contradicts PMCPS‑C §§105-106 (documentary and filing obligations). PMCPS‑M §202(b) explicitly takes applicability from PMCPS‑C §104 and §105 and therefore requires resolution of the contradiction. This change responds to the meeting agenda item that required resolving the contradiction so PMCPS‑M §202(b) has a stable reference. If previously proposed and rejected: none. - S008: Add explicit, verifiable evidence requirements for resolution‑source independence and for preserving the contemporaneous output of any resolution source at settlement. Make the following inserts to PMCPS‑M: 1) Add a new paragraph to §502 as (e): "(e) Documentary proof of independence and contemporaneous capture. For every resolution source identified in a contract's resolution specification under §501, a covered operator shall retain and produce on request all of the following: (1) a written conflict‑of‑interest and independence statement for the resolution source, signed by an authorised representative of the source or, where that is unavailable, a completed and signed operator‑maintained conflict checklist describing known affiliations or commercial relationships between the source and the operator or its affiliates; (2) a contemporaneous archival capture of the exact item consulted at settlement (for machine‑accessible sources: the full response body, HTTP headers, retrieval timestamp in UTC, the request used, and the cryptographic hash of the response; for human or non‑machine sources: a contemporaneous signed PDF transcript, audio recording, or equivalent record together with the operator's contemporaneous explanation of the retrieval method), and the operator's retention of that capture in content‑addressed storage; (3) metadata tying the archival capture to the settled contract and to the specific settlement action (contract identifier, settlement timestamp, settlement transaction id); and (4) where the resolution source is legal entity‑affiliated with the operator or otherwise fails independence in (1), the contract must instead name a pre‑identified independent adjudicator as permitted by §501(a)(4)." 2) Add a new item to §601(a) retention list: after (11) insert a new (12): "(12) the archival captures and retrieval metadata required by §502(e), retained in content‑addressed form for not less than five years." Additionally, add an advisory sentence at §501(d) or §502(c) (whichever is more consistent with the document's drafting conventions) noting that "the archival capture and independence documentation required by PMCPS‑M §502(e) are the evidentiary artefacts an assessor will request to verify compliance with the independence and settlement integrity obligations in Part 500." Rationale: §501 and §502 require publication of a resolution specification and, in some cases, permit the operator to be the resolution source subject to review. Those obligations lack a clear, verifiable evidentiary standard showing how an assessor proves independence or what exactly must be retained to show the operator applied the stated resolution source at settlement. Without contemporaneous capture plus an independence disclosure, an assessor cannot reconstruct what the operator consulted or whether the source was independent. Requiring the cheap, automatable step of snapshotting the consulted output plus a signed independence statement closes that evidentiary gap with the least costly implementation: a simple HTTP/API GET and storage of the response plus metadata and hash (or recording a signed transcript for human sources). Evidence: PMCPS‑M §501(a)(2), §501(a)(6), and §502(c) (current text) require resolution specification, time of consultation, and permit operator as source in narrow cases but do not define the contemporaneous archival artefacts an assessor needs. The S006 change passed in Session 2026‑09‑09 added "resolution specification" and recording its cryptographic hash; this suggestion builds on that by prescribing the settlement‑time capture and independence documentary proof that assessors will need to verify compliance. Independent testing requirements in §208 and retention requirements in §601 support adding a specific retention item for these artefacts. Practical implementation (cheapest path) is an archival HTTP/API fetch and storage; where a source refuses machine capture the operator must instead keep a signed contemporaneous attestation. If previously proposed and rejected: The board previously passed S006 (session 2026‑09‑09) requiring a resolution specification and hash; that proposal did not require settlement‑time archival captures. That proposal passed, not rejected. No prior rejection of this specific archival capture + independence documentation requirement. - S009: Remove: PMCPS-M § 304(d): "A covered operator shall contribute to the funding of problem gambling research, prevention, and treatment. The contribution shall be calculated as a stated percentage of gross gaming revenue or an equivalent measure, shall be disclosed publicly, and shall be paid to an entity independent of the covered operator." Rationale: This is a fiscal policy allocation, not an internal-control obligation. It is jurisdiction-sensitive (tax/levy or regulatory-choice), currently lacks a specified rate or base (creating ambiguity about what evidence demonstrates compliance), and imposes cross-border funding and beneficiary‑selection requirements that cannot be administered uniformly by an assessor or by an operator acting alone. Retaining robust problem-gambling operational controls (planning, triggers, exclusion, limits, reporting) achieves the consumer-protection objective without prescribing a funding mechanism better set by an adopting authority. Removing the mandatory contribution obligation preserves assessable, implementable controls while avoiding an unverifiable, policy-level mandate.

The Participant Advocate (openai:gpt-5-mini) - S010: Amend PMCPS-M § 501(a)(7) and PMCPS-M § 601 as follows (replace existing § 501(a)(7) with the paragraph below and add the new subparagraph to § 601): - New text for PMCPS-M § 501(a)(7): "Before the participant submits an order, and again in the order confirmation message, the covered operator shall present the following facts to that participant in both human-readable form and as a machine-readable file linked from the UI: (A) the resolution source by name and unique machine identifier (e.g., URL and content-addressed identifier); (B) the single-sentence plain‑language settlement condition derived from § 501(a)(1); (C) the exact Coordinated Universal Time at which the resolution source will be consulted under § 501(a)(3); (D) whether the resolution source is independent of the covered operator or is the covered operator, an affiliate, or a person compensated by the covered operator; and (E) whether that resolution source or the contract type is currently subject to a known regulatory review, prohibition, or stay. In addition, for each order submitted the covered operator shall: (1) create an immutable, time‑stamped, content‑addressed record (UI snapshot) that captures the exact human-readable text and the machine-readable file presented to that specific participant on the order-entry screen and the exact order-confirmation message delivered to that participant; the record must include the participant account identifier, order identifier, the system timestamp, and the cryptographic hash of the machine-readable resolution specification; and (2) retain that UI snapshot as part of the participant's records for not less than five years and make it accessible to the participant for download from their account history without contacting customer service; the operator shall provide a persistent link to the stored snapshot in the order confirmation and in the participant's on‑account order history." - New subparagraph to PMCPS-M § 601 (add as § 601(a)(12)): "(12) the UI snapshots and machine-readable files created under § 501(a)(7), each retained for not less than five years and made accessible to the participant as required by § 501(a)(7)." State plainly: this replacement does not remove any existing record retention obligations but adds the explicit evidence required to prove compliance with § 501(a)(7) and the participant-facing download right. Rationale: PMCPS-M § 501(a)(7) already requires particular facts to be presented pre-trade, but the Standards do not currently state what record proves those facts were in fact presented to that participant at that moment. Without a verifiable, participant‑tied UI snapshot, participants cannot reliably demonstrate what they were told when contesting a settlement or asserting mis‑disclosure; assessors cannot verify pre-trade disclosure compliance from backend evidence alone. Requiring a time‑stamped, content‑addressed snapshot (human text + machine-readable file) creates clear, producible evidence that the participant actually received the exact disclosure, and gives the participant immediate access to the same record they will rely on in a § 504 settlement contest. This change both protects participants (they can retrieve what they were told to support disputes) and makes the obligation verifiable without prescribing enforcement mechanics. Evidence: PMCPS-M § 501(a)(7) currently lists the facts to be presented pre‑trade; PMCPS-M § 601 lists records to be retained but does not name UI presentation snapshots. S007 (passed 2026‑09‑09) added pre‑trade facts to be presented; the CFTC Proposed Rule and CFTC DMO advisory (June 12, 2026 and Mar. 12, 2026) emphasise pre‑trade identification of settlement data sources and transparency supporting contest procedures (external intel in meeting history). The lack of an explicit evidence artifact for what was presented to the participant is a gap between the obligation to present facts and the assessor's ability to verify that the operator complied. - S011: Amend PMCPS-C § 102(a) to resolve the internal contradiction by replacing the sentence "This standard determines scope. It imposes no requirement on the design, operation, or conduct of a covered operator." with the following operative text: - New PMCPS-C § 102(a) text: "This standard determines scope and the conditions under which the PMCPS family applies. Except as expressly stated in §§ 105 and 106 (which impose classification, recordkeeping, signature, filing, retention, and reclassification obligations on a covered operator), this standard does not prescribe technical system behaviours, product design, or operational controls. The record, filing, and signature obligations set out in §§ 105 and 106 are operative obligations on a covered operator and may be relied on by PMCPS-M for applicability and enforcement of the minimum internal control standards." Add explanatory cross‑reference sentence at the end of PMCPS-C § 102: "For clarity, PMCPS-M § 202(b) takes applicability from PMCPS-C § 104; the classification obligations in §§ 105-106 are therefore operative and necessary preconditions for PMCPS-M obligations to apply." State plainly: this edit removes the absolute statement that no requirement is imposed and replaces it with a narrow rule that classification imposes only the specified classification/recording/filing obligations (not technical/system design), thereby aligning PMCPS-C with the express obligations in §§ 105-106 and preserving PMCPS-M § 202(b)'s cross-reference. Rationale: PMCPS-C § 102(a) currently says the classification standard imposes no requirement on design, operation, or conduct, but §§ 105 and 106 impose mandatory written classification, filing, signature, retention, and reclassification duties on covered operators. The contradiction makes the standard inapplicable as published and creates uncertainty about whether PMCPS-M § 202(b) can lawfully take its applicability from PMCPS-C. Participants rely on classification-driven disclosures and rights (e.g., the pre‑trade facts in PMCPS-M § 501(a)(7) and the contest rights in § 504). Clarifying that PMCPS-C imposes only the classification and recordkeeping obligations in §§ 105-106 resolves the textual conflict, preserves the operator duties that enable participants to access classification‑based protections, and makes PMCPS-M's dependency explicit and administrable. Evidence: The contradiction is on the meeting agenda: PMCPS-C § 102(a) vs. §§ 105/106 (agenda item). PMCPS-M § 202(b) explicitly takes applicability from PMCPS-C § 104; unless PMCPS-C acknowledges the classification record and filing duties as operative, PMCPS-M cannot unambiguously apply. PMCPS-C §§ 105-106 already impose signature, filing, retention, and reclassification duties; this suggestion simply reconciles the prefatory statement with those operative provisions. - S012: Remove: PMCPS-C § 102(a): "This standard determines scope. It imposes no requirement on the design, operation, or conduct of a covered operator." (quoted/paraphrased) Rationale: Section 102(a) is internally inconsistent with the rest of PMCPS-C. Sections 105 and 106 impose clear, operative obligations on a covered operator (make, record, file, and re-do classification determinations), so the blanket statement that the classification standard "imposes no requirement" is false, confusing, and renders the text unworkable for operators, assessors, and regulators. From a participant-advocate perspective, the clause undermines accountability: it suggests operators need not create or preserve the records and processes the PMCPS family relies on to protect participants and to enable assessment and remediation. Removing §102(a) resolves the contradiction that prevents the standard from being applied as published and preserves the intended functioning of PMCPS-M §202(b), which takes applicability from PMCPS-C §104 and relies on classification records. No substantive protective requirement is lost by removal-only a misleading disclaimer-so the standard becomes internally consistent and enforceable as drafted elsewhere.

The Settlement and Integrity Specialist (claude:claude-haiku-4-5) - S013: Amend PMCPS-M § 501(a)(6) to require that the period within which a correction under § 503(b) or § 503(b-1) may be made shall not exceed fourteen calendar days from the date of settlement publication, and amend § 503(b-1) to require that a covered operator shall notify affected participants of any resolution source revision within twenty-four hours of learning of it, together with a plain-language explanation of the revision and its effect on settlement, and shall permit participants to contest the revised settlement under § 504 notwithstanding that the original settlement was already published. Rationale: Section 503(b-1), adopted at the September 9 meeting, permits a covered operator to correct a settlement where the resolution source revises its determination. That provision has no time limit on when the operator must act, and the participant has no explicit right to contest the revised settlement. The Polymarket MicroStrategy case (June 4, 2026) illustrates the risk: a market resolved "No" based on an oracle vote, but the operator's reliance on that oracle determination was never tested against the participant's right to challenge it when facts changed. The CFTC's June 12, 2026 proposed market integrity factor explicitly requires "defined dispute-resolution protocols" and documented settlement feeds. Without a hard deadline and an explicit contest right tied to the revision, § 503(b-1) creates a window during which the operator can delay notification, suppress participant knowledge of the revision, and effectively rewrite settlement unilaterally. The fourteen-day window aligns with the contest period in § 504(a) and prevents indefinite tail risk for participants. Evidence: PMCPS-M § 503(b-1) (adopted Sept 9, 2026); § 504(a) (fourteen calendar day contest window); external intel: Polymarket MicroStrategy case (June 4, 2026); Federal Register - CFTC Proposed Rules: Market Integrity Factor for Event Contracts (June 12, 2026), 91 Fed. Reg. 11854, requiring "defined dispute-resolution protocols"; Lawsuit Against Polymarket (July 8, 2026) alleging effective post-hoc rule change. - S014: Amend PMCPS-C § 102(a) to read: "This standard determines scope and imposes the obligations stated in § 105. It imposes no other requirement on the design, operation, or conduct of a covered operator. Those requirements are stated in PMCPS-M and, when issued, PMCPS-T." Correspondingly amend PMCPS-M § 202(b) to add: "The classification determination required by PMCPS-C § 105 is itself an obligation imposed on a covered operator by these Standards; compliance with PMCPS-C § 105 is a requirement of PMCPS-M applicability." Rationale: PMCPS-C § 102(a) states that the standard "imposes no requirement on the design, operation, or conduct of a covered operator," but PMCPS-C § 105 imposes five obligations: make a written classification determination (§ 105(a)), record specified items (§ 105(b)), sign it (§ 105(c)), file it where required (§ 105(d)), and update filings on reclassification (§ 105(e)). The text cannot be applied as published while both statements stand. This contradiction was flagged on the agenda for this meeting. The conflict is material: if § 102(a) is read literally, an operator has no obligation to make or file a classification determination, which defeats the stated purpose of § 105 (converting the test "from an analytical exercise into an operating requirement," per the drafting note). The resolution is to clarify that § 105's obligations are classification obligations, not operating obligations, and that they are imposed on the covered operator by PMCPS-C itself, not by PMCPS-M. This preserves the distinction between classification (PMCPS-C) and operating requirements (PMCPS-M) while making clear that classification is mandatory. PMCPS-M § 202(b) already requires that a covered operator make and file the classification determination; the amendment makes explicit that this requirement is a bridge obligation, binding both documents. Evidence: PMCPS-C § 102(a) vs. § 105(a), (d), (e); PMCPS-C § 105 drafting note ("Paragraph (a) is what converts this standard from an analytical exercise into an operating requirement"); PMCPS-M § 202(b) (already requires the determination to be made and filed); agenda item: "Resolve the contradiction in PMCPS-C. Section 102(a) states that the standard imposes no requirement on the design, operation, or conduct of a covered operator. Sections 105 and 106 impose seventeen obligations on a covered operator."

The Minimal Intervention Advocate (claude:claude-haiku-4-5) - S015: Amend PMCPS-C § 104(g)(1) to read: "offered under a licence issued by a gaming regulatory authority that imposes requirements at least equivalent to Parts 300 through 500 of these Standards and supervises compliance with them, provided that (i) the operator documents the basis for claiming equivalence, (ii) the adopting regulatory authority has made a written determination that the licensing regime meets the equivalence standard, and (iii) that determination is filed with the operator's assessor before the product is first offered." Replace the current language in PMCPS-C § 105(b)(5) with: "where an exclusion under § 104(g)(1) is relied on, the licence relied on, the adopting authority's written equivalence determination, and the date of that determination." Add to PMCPS-C § 106(a) a new trigger: "(5) withdrawal or material modification of an equivalence determination made under § 104(g)(1)." Rationale: Section 104(g)(1) currently permits an operator to self-judge whether its licensing regime is "at least equivalent" to PMCPS-M Parts 300-500. This converts a scope exclusion into a self-administered waiver. The operator has a direct financial incentive to find equivalence, and an assessor examining the claim has no binding standard for verification. The result is that products that should trigger PMCPS-M requirements (exclusion, limits, problem gambling funding, influencing-person restrictions, settlement dispute procedures) may escape them based on an operator's unilateral assertion. This is the only gate in § 104 where the operator determines its own applicability. PMCPS-C § 102(a) states that the standard imposes no requirement on the operator; § 104(g)(1) as drafted delegates a classification determination to the operator and then makes it operative without external review. Evidence: PMCPS-C § 104(g)(1) text; PMCPS-C § 102(a) (scope statement); PMCPS-C Appendix C item 3 (open question on whether equivalence should require operator determination or certifying-body determination); CFTC Proposed Rule on Prediction Markets (June 12, 2026), which emphasizes "clear, objective, and publicly verifiable" criteria and factor-based review rather than operator self-certification; the rejection of S012 at the Sept 9 meeting, which noted that removing mandatory external review weakens assurance and shifts burden to assessors-here, the problem is that the assurance model itself is absent at the gate level. - S016: Amend PMCPS-M § 405(b) to read: "A covered operator shall engage an independent integrity monitor that is not an affiliate and has no financial interest in the covered operator's trading volume, unless the covered operator demonstrates, and the assessor accepts, that equivalent protections against the harms addressed by this section are achieved through the combination of (i) the automated surveillance required by § 405(a), (ii) the disclosure required by § 405(a-1), (iii) the incident reporting required by § 405(c), and (iv) the assessor review required by § 604. Where an assessor or an applicable regulatory authority subsequently identifies material gaps in surveillance effectiveness, manipulation detection, 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. This provision shall sunset on [date 24 months from these Standards' effective date] unless, before that date, an adopting regulatory authority or the Institute publishes evidence that operators relying on the alternative pathway have experienced materially higher rates of undetected market abuse, cross-platform misconduct, or settlement manipulation as compared to operators maintaining an independent monitor." Add a new subsection § 405(b-1): "Evidence supporting a waiver under paragraph (b) shall include: (1) the surveillance methodology and rulebook under § 405(a-1), demonstrating detection of at least one true positive and one false positive in the preceding twelve months; (2) the mean time to detect and mean time to respond metrics for each surveillance rule; (3) the incident reports filed under § 405(c) in the preceding twelve months, with remediation records; (4) the assessor's written conclusion that surveillance and reporting gaps, if any, do not materially impair detection of conduct prohibited by § 401; and (5) a written commitment that the operator will reinstate an independent monitor within thirty days if the assessor identifies material gaps in a subsequent review under § 604." Retain the current § 405(b) text (the independent monitor requirement and its scope, deliverables, and reporting obligations) as the baseline, and make it operative unless and until a waiver is granted under the amended paragraph (b). Rationale: The Sept 9 rejection of S012 rested on the principle that removing the mandatory external integrity monitor weakens assurance and shifts burden to assessors. That objection is sound: an external monitor is a structural, independent safeguard. However, the current text imposes the requirement without evidence that it addresses a harm that cannot be mitigated by surveillance, disclosure, and assessor review. The CFTC's own enforcement record (CFTC Division of Enforcement Advisory, Feb. 25, 2026) shows that existing CEA § 6(c)(1) and Rule 180.1 already cover insider misuse, wash trades, and disruptive practices on DCM-listed prediction markets. A requirement that does not demonstrably achieve a protection it claims must earn its place. The standard should retain the external monitor as the baseline (preserving the assurance model the Sept 9 board valued) but permit waiver where an operator demonstrates equivalent protections through surveillance, disclosure, and assessor review, with a sunset clause requiring evidence that the alternative pathway works before it becomes permanent. This respects the board's concern while applying the minimal-intervention principle: do not impose a prescriptive control where a less restrictive, evidence-based alternative addresses the same harm. Evidence: PMCPS-M § 405(b) current text; CFTC Division of Enforcement Advisory (Feb. 25, 2026), stating that CEA § 6(c)(1) and Rule 180.1 already cover the conduct § 401 prohibits; Sept 9 rejection of S012, noting that mandatory external monitors provide "a durable public-interest check on cross-platform misconduct" and that removal would "shift excessive burden to assessors"; PMCPS-M § 405(a-1) (surveillance evidence requirement, added at v1.2), which now makes surveillance methodology and results auditable; PMCPS-M § 604 (assessor review), which provides a periodic check; the board's mission statement, which directs that "a requirement degrading the price-discovery function must earn its place" and that obligations adopted without evidence should be removed or replaced with less restrictive means. - S017: Remove: PMCPS-M § 304(d): "A covered operator shall contribute to the funding of problem gambling research, prevention, and treatment. The contribution shall be calculated as a stated percentage of gross gaming revenue or an equivalent measure, shall be disclosed publicly, and shall be paid to an entity independent of the covered operator." Rationale: The harm this requirement was written to prevent is underfunding of problem gambling research, prevention, and treatment. That harm is already addressed by PMCPS-M § 304(a)-(c), which requires a written problem gambling plan, employee training, participant education, data-driven identification of at-risk participants, and phased interventions. These obligations create operational incentives for the operator to invest in effective identification and treatment referral, and create accountability through quarterly reporting under § 602(b)(3) and annual assessment under § 604(c). The funding requirement adds a separate, unrelated obligation. It imposes a levy on a covered operator, but: 1. No federal mechanism exists. The prefatory note acknowledges this. State gaming regimes fund these programs through gaming tax allocations. A federal derivatives operator has no tax mechanism into which to pay. The requirement therefore cannot be implemented without creating an ad-hoc funding structure, which is not the board's function. 2. It is unverifiable in these Standards. The obligation states the contribution "shall be calculated as a stated percentage" but does not specify the percentage, does not define "gross gaming revenue" for a derivatives operator, and does not specify which entity qualifies as "independent." An obligation that cannot be assessed is one that should not exist. 3. It is a policy choice outside scope. Whether prediction market operators should contribute to a public fund, at what rate, and to which entity, is a question for a regulatory authority that has adopted these Standards and has fiscal authority. This board is not that authority. The standard can require the operator to maintain a problem gambling plan and be assessed against it; it cannot impose a levy. A less restrictive means addresses the same harm: require disclosure of the operator's actual spending on problem gambling research, prevention, and treatment as part of the annual report under § 602(b). This preserves transparency and accountability without imposing an unimplementable levy or deferring to an undefined external mechanism.

1b. Removal Duty

Every seat must nominate one existing obligation for removal, or name the one it considered and say why it stays.

• The Derivatives Regulator nominated S003: Remove: PMCPS-M § 304(d): "A covered operator shall contribute to the funding of problem gambling research, prevention, and treatment. The contribution shall be calculated as a stated percentage of gross gaming revenue or an equivalent measure, shall be disclosed publicly, and shall be paid to an entity independent of the covered operator." Reason: This obligation imposes a quasi‑tax/levy on operator revenue and allocates public‑policy funding responsibility to private market operators. For an operator that is a registered designated contract market (DCM) under the Commodity Exchange Act, this duty collides with the Commission’s existing financial and reporting framework and with the limits on imposing industry‑wide levies outside statutory authority. It is also not administrable uniformly across jurisdictions (national, state, tribal) where funding mechanisms, tax rules, and authorized recipients differ. The provision therefore creates legal and compliance conflicts for DCMs and cannot be verified by evidence that would be consistent across adopting authorities. The standard is better without a mandatory contribution; if an adopting authority wishes to require funding, that should be done by statute or by the adopting regulator, not as a minimum internal control imposed on every covered operator.
• The State Gaming Regulator nominated S006: Remove: PMCPS-M § 301(d)(1), the one-time optional liquidation offer > "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 which, if elected, will attempt to close the participant's open positions at a firm reference price." Reason: As a state gaming regulator, I have implemented exclusion programs in Ohio and other jurisdictions. The obligation to offer a liquidation at a reference price creates three regulatory problems: 1. Operational ambiguity in a market context. In fixed-odds wagering, a position cannot be sold; exclusion simply preserves the right to be paid. A transferable position creates a new harm: the excluded participant bears continuing market risk. But the drafting note acknowledges this is unresolved (Appendix A item 1). Mandating a liquidation offer before that question is settled locks the standard into a solution that may not be correct. 2. Perverse incentive. An excluded participant who declines the liquidation offer and then suffers a loss may argue that the operator failed to adequately present the option, creating dispute and litigation. An operator facing that exposure will over-offer, and an excluded participant facing pressure to decide in thirty days may accept a reference price worse than they could obtain through risk-reducing orders. The supposed protection becomes a trap. 3. Gaps in the requirement itself. The obligation does not specify what happens if the participant declines, what happens if the reference price moves materially between calculation and execution, or what happens if the market is illiquid. These are not details; they are the content of the obligation. An obligation stated without these details cannot be assessed. Alternative: Keep § 301(d) as drafted, but strike § 301(d)(1) and (d)(2). Retain only § 301(d) as the principle-"An excluded participant retains the right to receive any amount owed on a position"-and § 301(d)(2) as the mechanism-"permit an order that closes or reduces an open position." This gives the excluded participant the right to exit at market prices they choose, which is what exclusion requires. The operator's duty is to enforce that right, not to engineer a price.
• The Exchange Operator nominated S009: Remove: PMCPS-M § 304(d): "A covered operator shall contribute to the funding of problem gambling research, prevention, and treatment. The contribution shall be calculated as a stated percentage of gross gaming revenue or an equivalent measure, shall be disclosed publicly, and shall be paid to an entity independent of the covered operator." Reason: This is a fiscal policy allocation, not an internal-control obligation. It is jurisdiction-sensitive (tax/levy or regulatory-choice), currently lacks a specified rate or base (creating ambiguity about what evidence demonstrates compliance), and imposes cross-border funding and beneficiary‑selection requirements that cannot be administered uniformly by an assessor or by an operator acting alone. Retaining robust problem-gambling operational controls (planning, triggers, exclusion, limits, reporting) achieves the consumer-protection objective without prescribing a funding mechanism better set by an adopting authority. Removing the mandatory contribution obligation preserves assessable, implementable controls while avoiding an unverifiable, policy-level mandate.
• The Participant Advocate nominated S012: Remove: PMCPS-C § 102(a): "This standard determines scope. It imposes no requirement on the design, operation, or conduct of a covered operator." (quoted/paraphrased) Reason: Section 102(a) is internally inconsistent with the rest of PMCPS-C. Sections 105 and 106 impose clear, operative obligations on a covered operator (make, record, file, and re-do classification determinations), so the blanket statement that the classification standard "imposes no requirement" is false, confusing, and renders the text unworkable for operators, assessors, and regulators. From a participant-advocate perspective, the clause undermines accountability: it suggests operators need not create or preserve the records and processes the PMCPS family relies on to protect participants and to enable assessment and remediation. Removing §102(a) resolves the contradiction that prevents the standard from being applied as published and preserves the intended functioning of PMCPS-M §202(b), which takes applicability from PMCPS-C §104 and relies on classification records. No substantive protective requirement is lost by removal-only a misleading disclaimer-so the standard becomes internally consistent and enforceable as drafted elsewhere.
• The Minimal Intervention Advocate nominated S017: Remove: PMCPS-M § 304(d): "A covered operator shall contribute to the funding of problem gambling research, prevention, and treatment. The contribution shall be calculated as a stated percentage of gross gaming revenue or an equivalent measure, shall be disclosed publicly, and shall be paid to an entity independent of the covered operator." Reason: The harm this requirement was written to prevent is underfunding of problem gambling research, prevention, and treatment. That harm is already addressed by PMCPS-M § 304(a)-(c), which requires a written problem gambling plan, employee training, participant education, data-driven identification of at-risk participants, and phased interventions. These obligations create operational incentives for the operator to invest in effective identification and treatment referral, and create accountability through quarterly reporting under § 602(b)(3) and annual assessment under § 604(c). The funding requirement adds a separate, unrelated obligation. It imposes a levy on a covered operator, but: 1. No federal mechanism exists. The prefatory note acknowledges this. State gaming regimes fund these programs through gaming tax allocations. A federal derivatives operator has no tax mechanism into which to pay. The requirement therefore cannot be implemented without creating an ad-hoc funding structure, which is not the board's function. 2. It is unverifiable in these Standards. The obligation states the contribution "shall be calculated as a stated percentage" but does not specify the percentage, does not define "gross gaming revenue" for a derivatives operator, and does not specify which entity qualifies as "independent." An obligation that cannot be assessed is one that should not exist. 3. It is a policy choice outside scope. Whether prediction market operators should contribute to a public fund, at what rate, and to which entity, is a question for a regulatory authority that has adopted these Standards and has fiscal authority. This board is not that authority. The standard can require the operator to maintain a problem gambling plan and be assessed against it; it cannot impose a levy. A less restrictive means addresses the same harm: require disclosure of the operator's actual spending on problem gambling research, prevention, and treatment as part of the annual report under § 602(b). This preserves transparency and accountability without imposing an unimplementable levy or deferring to an undefined external mechanism.
• The Settlement and Integrity Specialist retained: PMCPS-M § 304(d), the problem gambling funding requirement. Why it stays: This obligation is the only structural mechanism in these Standards that addresses the gap identified in the Prefatory Note: that an operator satisfying every federal derivatives obligation will still fall short of protections a participant receives under state gaming regulation. State gaming regimes fund problem gambling research and treatment through gaming tax allocations. Federal derivatives law has no equivalent mechanism. § 304(d) closes that gap by requiring the operator to contribute, creating a revenue stream for prevention and treatment that would otherwise not exist. The obligation is operationally feasible-state gaming operators demonstrate this daily-and it is the most direct way to ensure that the harms these Standards address are met with funded responses. Removing it would leave a standard with extensive disclosure and exclusion requirements but no funding for the treatment and research those requirements are designed to support. It must stay.

2. Pool Phase

Leader actions: - S009 and S017 and S003 merged → S003 (authors credited: The Derivatives Regulator, The Exchange Operator, The Minimal Intervention Advocate) Merge note: All three submissions call for removal of the identical text of PMCPS-M §304(d) (the mandatory problem-gambling funding levy). The operative instruction in each submission is word-for-word the same removal; only the supporting rationale differs. S003 is kept as the representative wording; all three authors are credited. - S007 and S014 and S011 merged → S011 (authors credited: The Participant Advocate, The Exchange Operator, The Settlement and Integrity Specialist) Merge note: All three resolve the same PMCPS-C §102(a) internal contradiction by replacing the blanket 'no requirement' sentence with a carve-out confirming that §§105-106 classification/recordkeeping/filing/reclassification duties are operative, and all three preserve or restate the PMCPS-M §202(b) applicability link. S011's wording is kept because it is the most concise version that still explicitly covers both §105 and §106 and states the §202(b) cross-reference; S007 and S014 ask for the same functional outcome (S014 omits §106, S007's extra detail is folded into S011's shorter formulation). - 11 suggestion(s) retained as submitted

Final pool: 13 suggestions (from 17 submitted; 2 merged)

• S001: Replace PMCPS-C §102(a) with the following text, and add the specified documentary-evidence obligations to PMCPS-C §105(b) as shown. - New PMCPS-C §102(a) (replacement): "This standard determines scope. Except for the procedural recordkeeping and filing obligations set out in §105 and the reclassification obligations in §106, it imposes no operational design, system, or trading conduct requirements on a covered operator. The obligations in §105 and §106 are classification and records obligations and are enforceable as stated." - Amend PMCPS-C §105(b) by inserting at the end of the paragraph the following requirement (to be read as part of §105(b)): "The written determination shall be accompanied by, and the covered operator shall retain and produce on request the following supporting documentary evidence sufficient for an assessor or any applicable regulatory authority to verify the classification: (i) the product specification and full settlement terms relied on for the determination; (ii) the machine‑readable resolution specification required by PMCPS‑M §501(a)(7) and its cryptographic hash; (iii) an evidence map that links each conclusion reached under Gates 1-4 to contemporaneous source documents or records (for example: order‑book snapshots or trade-history extracts showing tradability and market‑determined prices under Gate 3; screenshots or product rules showing whether operator quotes are unilateral under Gate 3; participant account records or declarations relied on to establish a hedging nexus under Gate 4); (iv) where an equivalence exclusion under §104(g)(1) is claimed, a copy of the licence relied on and the operator's documented equivalence analysis and supporting materials; (v) the participant‑facing disclosure materials or screen mockups shown to participants at order entry for the product, including the resolution‑source identifier used at order entry; and (vi) documentary evidence of the identity and authority of the signatory required by §105(c) and proof of the signatory's designation under PMCPS‑M §204(a). These supporting materials shall be retained for the period stated in §105(f) and produced to an assessor or any applicable regulatory authority on request."
• S002: Replace PMCPS‑M §208(d) (the Alternative pathway for a registered designated contract market) with the following text to align explicitly with the Commodity Exchange Act and 17 C.F.R. Parts 38 and 40, and to define the evidence a DCM must produce for assessors: - New PMCPS‑M §208(d) (replacement): "Alternative pathway for a registered designated contract market. Where the covered operator is a registered designated contract market (DCM) under the Commodity Exchange Act, the DCM may satisfy paragraphs (a)-(c) by producing, in lieu of a separate independent laboratory certification, the contemporaneous filings, attestations, testing artifacts, and independent reports the DCM is required to generate or files voluntarily under the Commodity Exchange Act and 17 C.F.R. Parts 38 and 40, subject to the following requirements: (1) The DCM shall produce date‑stamped copies of all filings and attestations submitted to the Commission that relate to system safeguards, system testing, product self‑certification, or other testing of systems that map to PMCPS‑M §207 (including but not limited to attestations and testing performed under 17 C.F.R. §§38.1050-38.1051 and any Part 40 self‑certification submissions). (2) The DCM shall produce any independent laboratory reports relied upon in those filings, and the laboratory credentials and scope of accreditation for those reports. (3) The DCM shall produce an explicit mapping (a matrix) that ties each CFTC filing, testing artifact, attestation, and independent report to the specific PMCPS‑M §207 obligation(s) it covers, including the test cases, system build version, and dates of testing. (4) Where any PMCPS‑M §207 element is not demonstrably covered in the Part 38/40 filings and artifacts, the DCM shall produce the additional test artifacts, remediation records, and retest evidence necessary to demonstrate compliance with that PMCPS‑M §207 element. (5) Where the Commission or its staff has issued a directive, stay, or advisory that affects the DCM's testing, monitoring, or listing practices (for example CFTC Staff Advisories regarding continuous monitoring, system safeguards, or product self‑certification), the DCM shall produce the directive or advisory and demonstrable evidence of contemporaneous compliance with it. (6) All materials produced under this paragraph shall be retained for five years and produced to an assessor or any applicable regulatory authority on request."
• S003: Remove: PMCPS-M § 304(d): "A covered operator shall contribute to the funding of problem gambling research, prevention, and treatment. The contribution shall be calculated as a stated percentage of gross gaming revenue or an equivalent measure, shall be disclosed publicly, and shall be paid to an entity independent of the covered operator." (merged from S003, S009, S017; credited: The Derivatives Regulator, The Exchange Operator, The Minimal Intervention Advocate)
• S004: Amend PMCPS-M § 602(a) to add a new reporting item (10): "the number of participants whose accounts were flagged by RG triggers under § 304(a)(10) but for whom the operator declined to designate 'at-risk' status, together with the five-year retained written explanation for each such declination, aggregated by trigger type and by explanation category." Amend PMCPS-M § 601(a)(9) to specify that the operator shall retain "the RG trigger event logs, the at-risk designation records, and the five-year retained explanations for each declination to designate at-risk status" as part of the problem gambling plan documentation.
• S005: Amend PMCPS-M § 501(a)(7) to require that the facts presented to the participant on the order-entry screen include: "(8) whether the resolution source has a documented track record of timely, unambiguous publication of determinations for at least twelve months prior to listing, and if not, the reasons the covered operator believes the source will perform reliably; and (9) the covered operator's policy for settlement correction under § 503(b) and (b-1), including the period within which a correction may be made and the procedure by which a participant may contest a settlement under § 504." Amend PMCPS-M § 505(a) to add a new item (7): "the covered operator has reviewed the resolution source's publication history, where available, and has documented its assessment that the source is capable of publishing determinations in accordance with the resolution specification."
• S006: Remove: PMCPS-M § 301(d)(1), the one-time optional liquidation offer > "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 which, if elected, will attempt to close the participant's open positions at a firm reference price."
• S008: Add explicit, verifiable evidence requirements for resolution‑source independence and for preserving the contemporaneous output of any resolution source at settlement. Make the following inserts to PMCPS‑M: 1) Add a new paragraph to §502 as (e): "(e) Documentary proof of independence and contemporaneous capture. For every resolution source identified in a contract's resolution specification under §501, a covered operator shall retain and produce on request all of the following: (1) a written conflict‑of‑interest and independence statement for the resolution source, signed by an authorised representative of the source or, where that is unavailable, a completed and signed operator‑maintained conflict checklist describing known affiliations or commercial relationships between the source and the operator or its affiliates; (2) a contemporaneous archival capture of the exact item consulted at settlement (for machine‑accessible sources: the full response body, HTTP headers, retrieval timestamp in UTC, the request used, and the cryptographic hash of the response; for human or non‑machine sources: a contemporaneous signed PDF transcript, audio recording, or equivalent record together with the operator's contemporaneous explanation of the retrieval method), and the operator's retention of that capture in content‑addressed storage; (3) metadata tying the archival capture to the settled contract and to the specific settlement action (contract identifier, settlement timestamp, settlement transaction id); and (4) where the resolution source is legal entity‑affiliated with the operator or otherwise fails independence in (1), the contract must instead name a pre‑identified independent adjudicator as permitted by §501(a)(4)." 2) Add a new item to §601(a) retention list: after (11) insert a new (12): "(12) the archival captures and retrieval metadata required by §502(e), retained in content‑addressed form for not less than five years." Additionally, add an advisory sentence at §501(d) or §502(c) (whichever is more consistent with the document's drafting conventions) noting that "the archival capture and independence documentation required by PMCPS‑M §502(e) are the evidentiary artefacts an assessor will request to verify compliance with the independence and settlement integrity obligations in Part 500."
• S010: Amend PMCPS-M § 501(a)(7) and PMCPS-M § 601 as follows (replace existing § 501(a)(7) with the paragraph below and add the new subparagraph to § 601): - New text for PMCPS-M § 501(a)(7): "Before the participant submits an order, and again in the order confirmation message, the covered operator shall present the following facts to that participant in both human-readable form and as a machine-readable file linked from the UI: (A) the resolution source by name and unique machine identifier (e.g., URL and content-addressed identifier); (B) the single-sentence plain‑language settlement condition derived from § 501(a)(1); (C) the exact Coordinated Universal Time at which the resolution source will be consulted under § 501(a)(3); (D) whether the resolution source is independent of the covered operator or is the covered operator, an affiliate, or a person compensated by the covered operator; and (E) whether that resolution source or the contract type is currently subject to a known regulatory review, prohibition, or stay. In addition, for each order submitted the covered operator shall: (1) create an immutable, time‑stamped, content‑addressed record (UI snapshot) that captures the exact human-readable text and the machine-readable file presented to that specific participant on the order-entry screen and the exact order-confirmation message delivered to that participant; the record must include the participant account identifier, order identifier, the system timestamp, and the cryptographic hash of the machine-readable resolution specification; and (2) retain that UI snapshot as part of the participant's records for not less than five years and make it accessible to the participant for download from their account history without contacting customer service; the operator shall provide a persistent link to the stored snapshot in the order confirmation and in the participant's on‑account order history." - New subparagraph to PMCPS-M § 601 (add as § 601(a)(12)): "(12) the UI snapshots and machine-readable files created under § 501(a)(7), each retained for not less than five years and made accessible to the participant as required by § 501(a)(7)." State plainly: this replacement does not remove any existing record retention obligations but adds the explicit evidence required to prove compliance with § 501(a)(7) and the participant-facing download right.
• S011: Amend PMCPS-C § 102(a) to resolve the internal contradiction by replacing the sentence "This standard determines scope. It imposes no requirement on the design, operation, or conduct of a covered operator." with the following operative text: - New PMCPS-C § 102(a) text: "This standard determines scope and the conditions under which the PMCPS family applies. Except as expressly stated in §§ 105 and 106 (which impose classification, recordkeeping, signature, filing, retention, and reclassification obligations on a covered operator), this standard does not prescribe technical system behaviours, product design, or operational controls. The record, filing, and signature obligations set out in §§ 105 and 106 are operative obligations on a covered operator and may be relied on by PMCPS-M for applicability and enforcement of the minimum internal control standards." Add explanatory cross‑reference sentence at the end of PMCPS-C § 102: "For clarity, PMCPS-M § 202(b) takes applicability from PMCPS-C § 104; the classification obligations in §§ 105-106 are therefore operative and necessary preconditions for PMCPS-M obligations to apply." State plainly: this edit removes the absolute statement that no requirement is imposed and replaces it with a narrow rule that classification imposes only the specified classification/recording/filing obligations (not technical/system design), thereby aligning PMCPS-C with the express obligations in §§ 105-106 and preserving PMCPS-M § 202(b)'s cross-reference. (merged from S011, S007, S014; credited: The Participant Advocate, The Exchange Operator, The Settlement and Integrity Specialist)
• S012: Remove: PMCPS-C § 102(a): "This standard determines scope. It imposes no requirement on the design, operation, or conduct of a covered operator." (quoted/paraphrased)
• S013: Amend PMCPS-M § 501(a)(6) to require that the period within which a correction under § 503(b) or § 503(b-1) may be made shall not exceed fourteen calendar days from the date of settlement publication, and amend § 503(b-1) to require that a covered operator shall notify affected participants of any resolution source revision within twenty-four hours of learning of it, together with a plain-language explanation of the revision and its effect on settlement, and shall permit participants to contest the revised settlement under § 504 notwithstanding that the original settlement was already published.
• S015: Amend PMCPS-C § 104(g)(1) to read: "offered under a licence issued by a gaming regulatory authority that imposes requirements at least equivalent to Parts 300 through 500 of these Standards and supervises compliance with them, provided that (i) the operator documents the basis for claiming equivalence, (ii) the adopting regulatory authority has made a written determination that the licensing regime meets the equivalence standard, and (iii) that determination is filed with the operator's assessor before the product is first offered." Replace the current language in PMCPS-C § 105(b)(5) with: "where an exclusion under § 104(g)(1) is relied on, the licence relied on, the adopting authority's written equivalence determination, and the date of that determination." Add to PMCPS-C § 106(a) a new trigger: "(5) withdrawal or material modification of an equivalence determination made under § 104(g)(1)."
• S016: Amend PMCPS-M § 405(b) to read: "A covered operator shall engage an independent integrity monitor that is not an affiliate and has no financial interest in the covered operator's trading volume, unless the covered operator demonstrates, and the assessor accepts, that equivalent protections against the harms addressed by this section are achieved through the combination of (i) the automated surveillance required by § 405(a), (ii) the disclosure required by § 405(a-1), (iii) the incident reporting required by § 405(c), and (iv) the assessor review required by § 604. Where an assessor or an applicable regulatory authority subsequently identifies material gaps in surveillance effectiveness, manipulation detection, 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. This provision shall sunset on [date 24 months from these Standards' effective date] unless, before that date, an adopting regulatory authority or the Institute publishes evidence that operators relying on the alternative pathway have experienced materially higher rates of undetected market abuse, cross-platform misconduct, or settlement manipulation as compared to operators maintaining an independent monitor." Add a new subsection § 405(b-1): "Evidence supporting a waiver under paragraph (b) shall include: (1) the surveillance methodology and rulebook under § 405(a-1), demonstrating detection of at least one true positive and one false positive in the preceding twelve months; (2) the mean time to detect and mean time to respond metrics for each surveillance rule; (3) the incident reports filed under § 405(c) in the preceding twelve months, with remediation records; (4) the assessor's written conclusion that surveillance and reporting gaps, if any, do not materially impair detection of conduct prohibited by § 401; and (5) a written commitment that the operator will reinstate an independent monitor within thirty days if the assessor identifies material gaps in a subsequent review under § 604." Retain the current § 405(b) text (the independent monitor requirement and its scope, deliverables, and reporting obligations) as the baseline, and make it operative unless and until a waiver is granted under the amended paragraph (b).

2b. Deliberation

9 of 13 items drew an objection. 7 were amended by their author.

S001

As submitted: Replace PMCPS-C §102(a) with the following text, and add the specified documentary-evidence obligations to PMCPS-C §105(b) as shown. - New PMCPS-C §102(a) (replacement): "This standard determines scope. Except for the procedural recordkeeping and filing obligations set out in §105 and the reclassification obligations in §106, it imposes no operational design, system, or trading conduct requirements on a covered operator. The obligations in §105 and §106 are classification and records obligations and are enforceable as stated." - Amend PMCPS-C §105(b) by inserting at the end of the paragraph the following requirement (to be read as part of §105(b)): "The written determination shall be accompanied by, and the covered operator shall retain and produce on request the following supporting documentary evidence sufficient for an assessor or any applicable regulatory authority to verify the classification: (i) the product specification and full settlement terms relied on for the determination; (ii) the machine‑readable resolution specification required by PMCPS‑M §501(a)(7) and its cryptographic hash; (iii) an evidence map that links each conclusion reached under Gates 1-4 to contemporaneous source documents or records (for example: order‑book snapshots or trade-history extracts showing tradability and market‑determined prices under Gate 3; screenshots or product rules showing whether operator quotes are unilateral under Gate 3; participant account records or declarations relied on to establish a hedging nexus under Gate 4); (iv) where an equivalence exclusion under §104(g)(1) is claimed, a copy of the licence relied on and the operator's documented equivalence analysis and supporting materials; (v) the participant‑facing disclosure materials or screen mockups shown to participants at order entry for the product, including the resolution‑source identifier used at order entry; and (vi) documentary evidence of the identity and authority of the signatory required by §105(c) and proof of the signatory's designation under PMCPS‑M §204(a). These supporting materials shall be retained for the period stated in §105(f) and produced to an assessor or any applicable regulatory authority on request."

Objections: - The Exchange Operator: Defect - the proposed evidence list is over‑prescriptive and, as drafted, requires raw participant/trade data and specific artifact types (e.g., "screenshots shown to participants at order entry", order‑book snapshots) that may not exist in continuous matching systems, may be confidential, and may not be the least‑cost means to prove the Gate conclusions. It also leans on PMCPS‑M references (§501(a)(7), §204(a)) without stating how those cross‑references are to be reconciled. Fix - change the paragraph to require an evidence map that (a) links each Gate conclusion to timestamps and categories of contemporaneous evidence (for example: UI disclosure version id and timestamp; order‑book snapshot or trade report identifier and timestamp; matching engine audit log excerpt; resolution spec versi - The Minimal Intervention Advocate: The evidence map requirement in proposed §105(b) asks assessors to verify "contemporaneous source documents" without defining what "contemporaneous" means in the context of classification. A classification determination may be made weeks or months after a product launches; the contemporaneous documents at launch (order-book snapshots, product rules) will be historical by the time the determination is signed and filed. The requirement should clarify whether "contemporaneous" means contemporaneous with the classification decision, contemporaneous with product launch, or contemporaneous with each Gate analysis, and should specify the retention period for each class of document independently. Without that clarification, an assessor cannot know whether the operator has complied or whether docum

Amended to: Replace PMCPS‑C §102(a) with the following text, and insert the following sentence at the end of PMCPS‑C §105(b) (to be read as part of §105(b)). New PMCPS‑C §102(a) (replacement) "This standard determines scope. Except for the procedural recordkeeping, filing, and classification‑documentation obligations set out in §105 and the reclassification obligations in §106, it imposes no operational design, system, or trading conduct requirements on a covered operator. The obligations in §105 and §106 are classification and records obligations and are enforceable as stated." Insertion to PMCPS‑C §105(b) (new evidence requirement) "The written determination shall be accompanied by, and the covered operator shall retain and produce on request, an evidence package sufficient for an assessor or any applicable regulatory authority to verify the classification. The evidence package must include: (i) an evidence map that links each discrete conclusion reached under Gates 1-4 to one or more contemporaneous source records or, where contemporaneous raw source records cannot be produced, to contemporaneous metadata, attestation, or validated system audit log excerpts; each link must identify the class of source evidence, a unique identifier for the record or extract relied on, and a timestamp for when the source evidence was created or captured; (ii) a copy of the product specification and full settlement terms relied on for the determination, or, where a substantially equivalent document exists within the operator's routine system of record (for example, a trade capture record, rulebook entry, or operational configuration file), a reference to that record together with the location and identifier in the evidence map; (iii) where the operator relies on a PMCPS‑M deliverable (for example, a machine‑readable resolution specification described in PMCPS‑M §501(a)(7) or proof of signatory designation under PMCPS‑M §204(a)), the operator shall either (A) produce the PMCPS‑M deliverable and any cryptographic hash it maintains, or (B) explain in the evidence map why the referenced PMCPS‑M provision is not applicable to this product and furnish the equivalent system record or attestation relied upon in its stead; (iv) examples of the participant‑facing disclosures or descriptions used at or about order entry, identified in the evidence map by version identifier and timestamp; where an operator cannot produce original participant display artifacts for confidentiality or system‑architecture reasons, the operator may provide a contemporaneous version identifier, a sanitized or redacted rendering, or a signed attestation describing the disclosure as presented and the method used to display it, together with the location and identifier used in the evidence map; (v) where the classification relies on participant position, hedging, or account relationship information, the evidence map must identify the category of account or ledger evidence relied on and provide, as appropriate, sanitized extracts, system identifiers, transaction identifiers, or attestations sufficient to permit verification without disclosing unnecessary confidential counterparty data; and (vi) documentary evidence of the identity and authority of the signatory required by §105(c) and evidence of that individual's designation in the operator's internal designation records (which may, where applicable, be the record required by PMCPS‑M §204(a)). For purposes of this paragraph, 'contemporaneous' means created at or within a reasonable timeframe of the event the Gate analysis relies upon (for example: documentation created at product launch for Gate 1; execution records for Gate 3 conclusions; system configuration records contemporaneous with the period of tradability evaluated). The evidence map must state the rationale for any date range relied on and identify the applicable retention period for each class of evidence. All materials in the evidence package must be retained for the period stated in §105(f). Where the covered operator is a designated contract market, clearing organization, or otherwise subject to federal recordkeeping obligations, the operator may satisfy the requirements of this paragraph by producing the records it is required to retain under applicable federal law (including, as applicable, 17 C.F.R. Parts 1, 38 and 40) together with an evidence map that links those federal records to the Gate conclusions. Where raw source records are unavailable to the assessor because they contain confidential participant data or are otherwise protected, the operator may supply redacted extracts, metadata, validated audit log excerpts, or attestations sufficient to permit verification; the operator must document in the evidence map the legal or operational basis for any redaction or limitation and provide a reasonable method by which an appropriate regulatory authority may obtain full records under that authority's legal powers." Author: I revised the original proposal to address both committee objections. - To answer the Exchange Operator's concern about over‑prescriptiveness and infeasible artifact types, I replaced the rigid list of required artifact types with an evidence‑map approach that requires categories, record identifiers and timestamps, and allows the operator to point assessors to the system of record (or to provide equivalent sanitized extracts, metadata, validated audit logs, or attestations) where raw participant/trade data or specific artifacts do not exist or cannot be produced. I preserved examples so assess

S002

As submitted: Replace PMCPS‑M §208(d) (the Alternative pathway for a registered designated contract market) with the following text to align explicitly with the Commodity Exchange Act and 17 C.F.R. Parts 38 and 40, and to define the evidence a DCM must produce for assessors: - New PMCPS‑M §208(d) (replacement): "Alternative pathway for a registered designated contract market. Where the covered operator is a registered designated contract market (DCM) under the Commodity Exchange Act, the DCM may satisfy paragraphs (a)-(c) by producing, in lieu of a separate independent laboratory certification, the contemporaneous filings, attestations, testing artifacts, and independent reports the DCM is required to generate or files voluntarily under the Commodity Exchange Act and 17 C.F.R. Parts 38 and 40, subject to the following requirements: (1) The DCM shall produce date‑stamped copies of all filings and attestations submitted to the Commission that relate to system safeguards, system testing, product self‑certification, or other testing of systems that map to PMCPS‑M §207 (including but not limited to attestations and testing performed under 17 C.F.R. §§38.1050-38.1051 and any Part 40 self‑certification submissions). (2) The DCM shall produce any independent laboratory reports relied upon in those filings, and the laboratory credentials and scope of accreditation for those reports. (3) The DCM shall produce an explicit mapping (a matrix) that ties each CFTC filing, testing artifact, attestation, and independent report to the specific PMCPS‑M §207 obligation(s) it covers, including the test cases, system build version, and dates of testing. (4) Where any PMCPS‑M §207 element is not demonstrably covered in the Part 38/40 filings and artifacts, the DCM shall produce the additional test artifacts, remediation records, and retest evidence necessary to demonstrate compliance with that PMCPS‑M §207 element. (5) Where the Commission or its staff has issued a directive, stay, or advisory that affects the DCM's testing, monitoring, or listing practices (for example CFTC Staff Advisories regarding continuous monitoring, system safeguards, or product self‑certification), the DCM shall produce the directive or advisory and demonstrable evidence of contemporaneous compliance with it. (6) All materials produced under this paragraph shall be retained for five years and produced to an assessor or any applicable regulatory authority on request."

Objections: - The Exchange Operator: Defect - the replacement text requires DCMs to produce unqualified artifacts (independent lab reports, system build versions, test artifacts) and an exhaustive mapping that may reveal proprietary system details or be unavailable in public filings; it does not provide for confidential handling of such materials or permit reasonable equivalents where a public filing omits implementation metadata. Fix - amend to permit (i) production of redacted artifacts or secure, confidential examiner access in lieu of full public disclosure; (ii) a mapping that ties CFTC filings and artifacts to PMCPS‑M §207 obligations by test identifier, test date, and scope without mandating disclosure of internal build pipelines (accepting vendor test‑IDs and test‑version markers as sufficient metadata); and (iii) a f

Amended to: "Alternative pathway for a registered designated contract market. Where the covered operator is a registered designated contract market (DCM) under the Commodity Exchange Act, the DCM may satisfy paragraphs (a)-(c) by producing, in lieu of a separate independent laboratory certification, the contemporaneous filings, attestations, testing artifacts, and independent reports the DCM is required to generate or files voluntarily under the Commodity Exchange Act and 17 C.F.R. Parts 38 and 40, subject to the following requirements: (1) The DCM shall produce date‑stamped copies of all filings and attestations submitted to the Commission that relate to system safeguards, system testing, product self‑certification, or other testing of systems that map to PMCPS‑M §207 (including but not limited to attestations and testing performed under 17 C.F.R. §§38.1050-38.1051 and any Part 40 self‑certification submissions). Where information contained in those materials is reasonably expected to reveal trade secrets, proprietary source code, or other confidential implementation details, the DCM may instead produce a redacted copy together with a contemporaneous unredacted‑access arrangement as described in paragraph (1)(b) below. The DCM shall accompany any redacted submission with a redaction log that (i) identifies each redacted item, (ii) states the basis for the redaction (for example: trade secret, third‑party confidential information), and (iii) cites the specific PMCPS‑M §207 element(s) for which the redacted item is claimed non‑material. (a) Unredacted‑access arrangement. In lieu of producing unredacted materials in public form, the DCM may provide secure, confidential access to unredacted materials to an assessor or an applicable regulatory authority under terms that preserve commercially sensitive information. Secure access may include (without limitation) on‑site review under controlled conditions, secure remote access to a read‑only environment, or review under a confidentiality protocol acceptable to the assessor or applicable regulatory authority. The DCM shall retain contemporaneous records evidencing the secure‑access arrangement (access logs, timestamps, and the identity of persons granted access). (2) The DCM shall produce any independent laboratory reports relied upon in those filings, and the laboratory credentials and scope of accreditation for those reports. If no independent laboratory report exists for an element that is covered by a filing or attestation, the DCM shall produce a contemporaneous explanation identifying the testing that was performed, the party that performed it, and why an independent laboratory report was not produced. (3) The DCM shall produce an explicit mapping (a matrix) that ties each CFTC filing, testing artifact, attestation, and independent report to the specific PMCPS‑M §207 obligation(s) it covers. The mapping shall identify, for each linked artifact, the test identifier(s), test date(s), and the scope or objective of the test. Where a system build version is material and available without disclosing proprietary implementation detail the mapping shall include the system build version and the date of the build; where a build‑version disclosure would reveal proprietary implementation details the DCM may instead provide vendor test identifiers, test‑version markers, or other vendor‑supplied markers used in the testing lifecycle as equivalent metadata. Where public filings omit implementation metadata, the DCM may supply a contemporaneous attestation describing the equivalence of the metadata it can provide to the metadata ordinarily requested by an assessor. (4) Where any PMCPS‑M §207 element is not demonstrably covered in the Part 38/40 filings and artifacts, the DCM shall produce the additional test artifacts, remediation records, retest evidence, or attestations necessary to demonstrate compliance with that PMCPS‑M §207 element. If full public disclosure of additional artifacts would disclose proprietary material, the DCM may satisfy this requirement by producing redacted artifacts together with secure unredacted access under paragraph (1)(a) and by supplying a redaction log. (5) Where the Commission or its staff has issued a directive, stay, or advisory that affects the DCM's testing, monitoring, or listing practices (for example CFTC Staff Advisories regarding continuous monitoring, system safeguards, or product self‑certification), the DCM shall produce the directive or advisory and demonstrable evidence of contemporaneous compliance with it. (6) The DCM shall retain all materials produced under this paragraph-including redaction logs and secure‑access records-for five years and shall produce them to an assessor or any applicable regulatory authority on request. Nothing in this paragraph relieves the DCM of any filing, recordkeeping, or production obligation the DCM otherwise has under the Commodity Exchange Act or 17 C.F.R. Parts 38 and 40, nor does it limit any statutory or regulatory authority of the Commission or an applicable regulatory authority to require unredacted materials when authorized to do so." Author: I revised the replacement text to address the Exchange Operator's confidentiality and availability objection. Changes: (1) permit redacted copies where disclosure would reveal trade secrets or proprietary implementation details; (2) require a redaction log and permit a secure, confidential unredacted‑access arrangement (on‑site or secure remote) to preserve assessor/regulatory access without public disclosure; (3) permit vendor test‑identifiers or test‑version markers in the mapping where disclosure of internal build pipelines would be proprietary, and allow an attestation where public filings

S003

As submitted: Remove: PMCPS-M § 304(d): "A covered operator shall contribute to the funding of problem gambling research, prevention, and treatment. The contribution shall be calculated as a stated percentage of gross gaming revenue or an equivalent measure, shall be disclosed publicly, and shall be paid to an entity independent of the covered operator."

Objections: - The State Gaming Regulator: The obligation you propose to remove does not fall within my remit as State Gaming Regulator. PMCPS-M § 304(d) addresses funding allocation and tax/levy policy, which are questions for the adopting authority and legislature, not for internal control standards. I defer to the seat responsible for problem-gambling architecture. However, I note that if this item passes, you must state whether it affects PMCPS-C § 105(b)'s documentary evidence requirements-specifically, whether an operator claiming compliance with a state gaming framework (e.g., Ohio Admin. Code ch. 3772-12) that does impose a contribution obligation can still satisfy PMCPS-M by reference to that framework under § 104(g)(1). If § 304(d) is removed but the adopting authority's own rules require the contribution, the operator fa - The Participant Advocate: Defect - deleting the mandatory contribution removes a concrete participant‑protection mechanism (funding for treatment/research) and eliminates any participant-facing fact about operator support for problem gambling remedies. Fix - do not remove. Instead amend §304(d) to permit jurisdictional alternatives but require the operator to disclose, at account opening and again on each product listing page before order entry, a machine‑readable and human‑readable statement that either (A) the operator contributes X% (or the stated formula) of gross gaming revenue to an independent treatment/prevention entity (name and recipient identifier included), or (B) the operator relies on an adopting authority’s equivalent funding mechanism (include the adopting authority’s written determination and date) - The Settlement and Integrity Specialist: This removal falls outside my scope. §304(d) imposes a funding obligation on covered operators, but it is a consumer-protection and policy-allocation provision, not a settlement-integrity, resolution-source-independence, or correction-procedure obligation. The instructions explicitly state I do not propose on "consumer protection wording, cost, licensing, or the classification gates." The merits of the funding requirement-whether it creates conflicts for DCMs or administrative friction across jurisdictions-are real, but they belong to a seat with jurisdiction over consumer protection and licensing frameworks, not to Settlement and Integrity. The objection is jurisdictional, not substantive.

Amended to: Replace PMCPS-M § 304(d) with the following text (self-contained replacement): (d) Funding mechanism; documentary evidence and federal review. (1) Options for covered operators. A covered operator must elect and maintain one of the following two funding-mechanism paths and must retain the documentary evidence specified in subparagraph (2). (A) Operator-funded mechanism. The covered operator shall adopt and maintain a written funding mechanism establishing contributions to problem‑gambling research, prevention, and treatment. The operator shall record the contribution formula or stated percentage (or equivalent measure), the legal name and identifier of the recipient entity(ies), a statement sufficient to demonstrate the recipient’s independence from the operator, the payment schedule, and records of payments made. The operator shall include copies of the funding mechanism, recipient independence documentation, and a payment accounting covering the immediately preceding 24 months in its PMCPS compliance documentation. (B) Adopting‑authority alternative. In lieu of an operator-funded mechanism, the covered operator may rely on an adopting authority’s funding mechanism or levy that the adopting authority has determined to be equivalent. To qualify under this path, the operator must obtain and retain a written determination, signed or otherwise formally issued by the adopting authority and dated, that the adopting authority’s mechanism provides funding equivalent to the operator-funded mechanism described in subparagraph (A). The operator’s PMCPS compliance documentation shall include that written determination and its date. (2) Recordkeeping and availability. The records and documents required by subparagraph (1) must be (i) retained in the operator’s PMCPS compliance documentation, and (ii) made available promptly to the adopting authority and to any federal authority that asserts jurisdiction and requests review. The operator shall update those records within 30 days of any material change affecting the funding mechanism, recipient independence, or relevant payments. (3) Designated contract market (DCM) conformity. If the covered operator is a DCM registered under the Commodity Exchange Act, the operator’s obligations under subparagraph (1) and the record‑filing obligations in subparagraph (2) are satisfied by reference to the operator’s public rule submissions, fee schedules, or comparable filings made under 17 C.F.R. Parts 38 or 40, provided the operator (A) cites the specific filings in its PMCPS compliance documentation, and (B) includes copies of the cited filings or directions to public locations where the filings are maintained. (4) Federal review and supplementary evidence. A federal authority that asserts jurisdiction may request and review the records required by this section to determine whether an adopting‑authority mechanism is equivalent to the operator‑funded mechanism. The federal authority may require supplementary evidence, including audits, certifications of payments, or additional documentary proof of recipient independence, to complete its review. *Author: I replaced the mandatory, operator‑only funding obligation with a verifiable, evidence‑centric requirement that changes (a) who is obligated to demonstrate compliance (the covered operator), (b) what evidence proves compliance (either operator’s written mechanism plus recipient independence and payment records, or an adopting authority’s written determination, all retained in the operator’s PMCPS compliance documentation), and (c) what a federal authority may do (request review and require supplementary evidence). This answers the State Gaming Regulator’s concern about how an operator relying *

S004

As submitted: Amend PMCPS-M § 602(a) to add a new reporting item (10): "the number of participants whose accounts were flagged by RG triggers under § 304(a)(10) but for whom the operator declined to designate 'at-risk' status, together with the five-year retained written explanation for each such declination, aggregated by trigger type and by explanation category." Amend PMCPS-M § 601(a)(9) to specify that the operator shall retain "the RG trigger event logs, the at-risk designation records, and the five-year retained explanations for each declination to designate at-risk status" as part of the problem gambling plan documentation.

Objections: - The Derivatives Regulator: Defect - mandates reporting of declination explanations without addressing participant privacy, re‑identification risk, or alignment with existing DCM/CFTC reporting formats. As written it could force operators to disclose sensitive account‑level reasons in a quarterly public report or to retain personally identifiable rationale in ways that conflict with privacy laws or with how DCMs already produce supervised reports to the Commission. What would fix it - require that the aggregated declination data be de‑identified and reported only in aggregate bands (or with minimum‑cell suppression) consistent with applicable privacy law; state that the quarterly report item may be satisfied by producing an assessor‑facing, de‑identified aggregate table plus a secure, examiner‑only vault of the under - The Minimal Intervention Advocate: The amendment requires quarterly reporting of declinations aggregated "by explanation category," but does not define what constitutes a category or who determines the taxonomy. An operator might report "business judgment" as one category; a regulator might expect "hedging nexus not established," "participant account records insufficient," "operator discretion." Without a pre-defined taxonomy or a requirement that the operator publish its categorization scheme in advance, assessors will lack a standard to verify whether the operator's reported categories are substantively meaningful or are being used to obscure patterns of inconsistent application. Fix: Add a requirement that the operator publish its declination-explanation taxonomy (the list of categories it will use in reporting) in its p

Amended to: Amend PMCPS-M § 602(a) to add a new reporting item (10): "the number of participants whose accounts were flagged by RG triggers under § 304(a)(10) but for whom the operator declined to designate 'at-risk' status, reported in the aggregate and de-identified consistent with applicable privacy law, aggregated by the operator's published declination-explanation taxonomy and presented in minimum-cell-suppressed bands where any cell contains fewer than five participants." Amend PMCPS-M § 601(a)(9) to specify that the operator shall retain "the RG trigger event logs, the at-risk designation records, and the five-year retained explanations for each declination to designate at-risk status, maintained in a de-identified format accessible only to the operator's compliance personnel and to authorized examiners." Add a new obligation to PMCPS-M § 301: "The operator shall publish, in its RG program documentation filed under § 601(a)(9), the complete declination-explanation taxonomy it uses to categorize reasons for declining at-risk designation. The taxonomy shall be established before the operator begins reporting under § 602(a)(10), shall remain stable for each calendar year, and shall be updated prospectively only." *Author: ** The first amendment answers the Derivatives Regulator's privacy and re-identification objection by requiring de-identification, privacy-law alignment, and minimum-cell suppression-standard DCM/CFTC practice for sensitive supervisory data. This keeps the data out of public quarterly reports and in examiner-only channels where appropriate. The second amendment answers the Minimal Intervention Advocate's taxonomy objection by requiring the operator to publish its declination-explanation categories in advance as part of the filed RG program. This gives assessors a verifiable standard: they can *

S006

As submitted: Remove: PMCPS-M § 301(d)(1), the one-time optional liquidation offer > "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 which, if elected, will attempt to close the participant's open positions at a firm reference price."

Objections: - The Participant Advocate: Defect - wholesale removal of the one‑time liquidation offer abandons excluded participants to continued market risk and creates asymmetry: participants lose a discrete, documented exit mechanism. Fix - do not delete the participant exit protection. Replace §301(d)(1) with a clear participant‑facing rule: at the moment an exclusion is enacted the operator shall present, in both human‑readable form and as a machine‑readable file linked from the UI (and recorded in the UI snapshot), the exit options available for that participant: (i) the right to place risk‑reducing or position‑closing orders themselves without penalty; and (ii) if the operator elects to offer a one‑time optional liquidation at a reference price, a plain‑language description of the liquidation procedure, the method for calc - The Settlement and Integrity Specialist: The defect is that the proposal asks me to remove an obligation without naming the obligation it replaces. The instruction states: "A suggestion that adds an obligation must name the existing obligation it replaces, by section, or state plainly that it replaces none." This proposal removes §301(d)(1) and (d)(2) but then proposes to retain §301(d) as "the principle" and as "the mechanism." That is unclear. If the proposal is to strike §301(d)(1) and (d)(2) entirely and replace them with nothing-leaving only the bare statement in §301(d) that an excluded participant retains the right to receive amounts owed-then say so plainly. If it is to replace the liquidation-offer obligation with a narrower obligation (permit risk-reducing orders only), name that replacement. As written, the proposal co

Amended to: Remove PMCPS-M § 301(d)(1) and § 301(d)(2) entirely. Replace § 301(d) with: "(d) Excluded Participant Position Management. An excluded participant retains the right to receive amounts owed under § 301(c). A covered operator shall, at the moment an exclusion is enacted: (1) permit the excluded participant to place risk-reducing orders and position-closing orders without penalty or additional margin requirement; (2) provide the excluded participant, in both human-readable form and as a machine-readable file linked from the UI and recorded in the UI snapshot, a clear statement of the exit options available under this subsection; and (3) if the operator elects to offer a one-time optional liquidation at a firm reference price, disclose in plain language: the liquidation procedure; the reference price method; the settlement timeline; and any fees or adjustments that will apply. The operator shall record this disclosure and the participant's acceptance or rejection in the UI snapshot." *Author: ** This amendment answers both objections by doing three things: First, it plainly states what is removed (§ 301(d)(1) and (d)(2), the mandatory one-time liquidation offer) and what replaces it (a three-part operator obligation: permit risk-reducing orders; disclose exit options in readable and machine-readable form; if offering liquidation, disclose its terms clearly). Second, it preserves the Participant Advocate's core protection-excluded participants get a documented, transparent exit mechanism with clear disclosure-while removing the mandatory liquidation offer that created asymmetry and *

S008

As submitted: Add explicit, verifiable evidence requirements for resolution‑source independence and for preserving the contemporaneous output of any resolution source at settlement. Make the following inserts to PMCPS‑M: 1) Add a new paragraph to §502 as (e): "(e) Documentary proof of independence and contemporaneous capture. For every resolution source identified in a contract's resolution specification under §501, a covered operator shall retain and produce on request all of the following: (1) a written conflict‑of‑interest and independence statement for the resolution source, signed by an authorised representative of the source or, where that is unavailable, a completed and signed operator‑maintained conflict checklist describing known affiliations or commercial relationships between the source and the operator or its affiliates; (2) a contemporaneous archival capture of the exact item consulted at settlement (for machine‑accessible sources: the full response body, HTTP headers, retrieval timestamp in UTC, the request used, and the cryptographic hash of the response; for human or non‑machine sources: a contemporaneous signed PDF transcript, audio recording, or equivalent record together with the operator's contemporaneous explanation of the retrieval method), and the operator's retention of that capture in content‑addressed storage; (3) metadata tying the archival capture to the settled contract and to the specific settlement action (contract identifier, settlement timestamp, settlement transaction id); and (4) where the resolution source is legal entity‑affiliated with the operator or otherwise fails independence in (1), the contract must instead name a pre‑identified independent adjudicator as permitted by §501(a)(4)." 2) Add a new item to §601(a) retention list: after (11) insert a new (12): "(12) the archival captures and retrieval metadata required by §502(e), retained in content‑addressed form for not less than five years." Additionally, add an advisory sentence at §501(d) or §502(c) (whichever is more consistent with the document's drafting conventions) noting that "the archival capture and independence documentation required by PMCPS‑M §502(e) are the evidentiary artefacts an assessor will request to verify compliance with the independence and settlement integrity obligations in Part 500."

Objections: - The Derivatives Regulator: Defect - requires a specific implementation detail ("content‑addressed storage") and prescribes technical system behavior (exact capture fields/formats) that belong to implementation/test‑procedure seats and may conflict with existing DCM recordkeeping practices under 17 C.F.R. Part 38. This oversteps the Board's remit to set verifiable evidentiary standards while avoiding technical mandates. What would fix it - replace the mandate for "content‑addressed storage" and exact capture mechanism with an evidentiary standard: require a tamper‑evident, time‑stamped archival record of the resolution source output and retrieval metadata, with cryptographic hashes and chain‑of‑custody logging sufficient for reconstructing the retrieval and for forensic verification by an assessor. Add a clause that

Amended to: Replace the previously-proposed insertion to PMCPS‑M with the following, to be added as new paragraphs and items at the cited locations. 1) Add new paragraph §502(e) (and renumber following subparagraphs if necessary): "(e) Documentary proof of resolution‑source independence and contemporaneous capture. For every resolution source identified in a contract's resolution specification under §501, a covered operator shall retain and produce on request the following evidentiary artefacts: (1) Independence documentation. Either (A) a written conflict‑of‑interest and independence statement for the resolution source, signed by an authorised representative of the source, or (B) where such a signed statement cannot reasonably be obtained, a completed and signed operator‑maintained conflict checklist describing known affiliations, commercial relationships, or other matters relevant to assessing the source's independence from the operator and its affiliates at the time the source was designated for use. (2) Contemporaneous capture of the item consulted at settlement. For each settlement action that uses a resolution source, the operator shall retain a contemporaneous archival capture of the exact item consulted at settlement together with retrieval metadata sufficient for an assessor to reconstruct the retrieval and verify integrity. For machine‑accessible resolution sources the capture and metadata shall include, at minimum: the full response body returned by the source; relevant transport and protocol metadata (for example HTTP headers where applicable); the exact request issued to the source; the retrieval timestamp expressed in coordinated universal time (UTC) with timezone indicator; and a cryptographic hash of the response body. For human or other non‑machine sources the capture and metadata shall include, at minimum: a contemporaneous signed transcript, audio recording, or other documentary record of the item consulted; the retrieval timestamp in UTC; and the operator's contemporaneous description of the method and identity of the person(s) who retrieved it. (3) Linkage metadata. Each archival capture required by (2) must be explicitly tied to the settled contract and to the specific settlement action that used it by recording the contract identifier, settlement timestamp, and internal settlement transaction identifier or equivalent. (4) Remediation where independence is lacking. Where the documentation produced under (1) shows that the resolution source is (or was at designation time) entity‑affiliated with the operator or otherwise fails to satisfy the applicable independence expectations, the contract's resolution specification must identify and bind a pre‑identified independent adjudicator or alternative independent source as permitted by §501(a)(4)." 2) Add new paragraph §502(f) (transitional compliance): "(f) Transition for live platforms. For covered operators that, on the effective date of this provision, have operational settlement workflows that did not previously produce all items required by §502(e), full compliance is required no later than twelve (12) months after that effective date. During the transition period the operator must preserve and produce any contemporaneous captures and metadata that were generated under existing practices, and shall provide a written interim statement of the steps being taken to achieve full compliance. For settled contracts whose settlement action occurred before the effective date of this provision, the operator shall, on assessor request, produce best‑effort reconstructions and any available contemporaneous records for the two (2) years preceding the effective date; where no contemporaneous record exists, the operator shall so attest." 3) Add advisory sentence at §502(c) (or insert as a short advisory paragraph immediately following §502): "The archival captures and independence documentation required by §502(e) are the evidentiary artefacts an assessor will request to verify compliance with the independence and settlement‑integrity obligations in Part 500." 4) Amend PMCPS‑M §601(a) retention list by inserting a new item (12) after current (11): "(12) the archival captures, retrieval metadata, independence documentation, linkage metadata, and any related chain‑of‑custody records required by §502(e), retained in tamper‑evident archival form with cryptographic hashes, time‑stamps, and chain‑of‑custody logging sufficient to permit forensic reconstruction and integrity verification by an assessor, for not less than five (5) years from the date of settlement." Notes on implementation scope within the normative text: - The provisions above specify required evidentiary content and minimal integrity controls (cryptographic hashes, UTC timestamps, chain‑of‑custody logging) but do not mandate a particular storage technology or vendor solution. Operators may satisfy the tamper‑evident and chain‑of‑custody requirements by any credible technical means (for example, append‑only/WORM storage with signed manifests and timestamped audit logs, notarisation, or equivalent measures) so long as the retained artefacts permit an assessor to verify provenance and integrity and to reconstruct the retrieval used at settlement. - These provisions are post‑settlement evidentiary and retention requirements. They require capture at or immediately after settlement and retention thereafter; they do not impose any verifiable obligation that can be enforced at the point of order entry because the content to be captured does not yet exist at entry time." Author: ** I replaced the original wording that mandated "content‑addressed storage" and prescriptive capture mechanics with an evidentiary standard that meets the Derivatives Regulator's objection. The amended text (a) preserves the original protection objectives - signed independence statements or operator conflict checklists, contemporaneous capture of the exact item used at settlement, linkage to the settled contract and settlement action, and a remediation path where independence is lacking - and (b) replaces the technical prescription with a requirement for tamper‑evident archival records, UTC t

S010

As submitted: Amend PMCPS-M § 501(a)(7) and PMCPS-M § 601 as follows (replace existing § 501(a)(7) with the paragraph below and add the new subparagraph to § 601): - New text for PMCPS-M § 501(a)(7): "Before the participant submits an order, and again in the order confirmation message, the covered operator shall present the following facts to that participant in both human-readable form and as a machine-readable file linked from the UI: (A) the resolution source by name and unique machine identifier (e.g., URL and content-addressed identifier); (B) the single-sentence plain‑language settlement condition derived from § 501(a)(1); (C) the exact Coordinated Universal Time at which the resolution source will be consulted under § 501(a)(3); (D) whether the resolution source is independent of the covered operator or is the covered operator, an affiliate, or a person compensated by the covered operator; and (E) whether that resolution source or the contract type is currently subject to a known regulatory review, prohibition, or stay. In addition, for each order submitted the covered operator shall: (1) create an immutable, time‑stamped, content‑addressed record (UI snapshot) that captures the exact human-readable text and the machine-readable file presented to that specific participant on the order-entry screen and the exact order-confirmation message delivered to that participant; the record must include the participant account identifier, order identifier, the system timestamp, and the cryptographic hash of the machine-readable resolution specification; and (2) retain that UI snapshot as part of the participant's records for not less than five years and make it accessible to the participant for download from their account history without contacting customer service; the operator shall provide a persistent link to the stored snapshot in the order confirmation and in the participant's on‑account order history." - New subparagraph to PMCPS-M § 601 (add as § 601(a)(12)): "(12) the UI snapshots and machine-readable files created under § 501(a)(7), each retained for not less than five years and made accessible to the participant as required by § 501(a)(7)." State plainly: this replacement does not remove any existing record retention obligations but adds the explicit evidence required to prove compliance with § 501(a)(7) and the participant-facing download right.

Objections: - The Derivatives Regulator: Defect - prescribes participant‑facing UI behavior (immediate downloadable access from account history) and an implementation model (persistent links, content‑addressed hash) that are operational/UX details outside this seat's remit and that may conflict with security, privacy, or existing DCM disclosure mechanics. The Standards should specify what evidence proves the pre‑trade disclosure was given, not the precise customer‑facing delivery method. What would fix it - retain the evidentiary requirement to create an immutable, time‑stamped UI snapshot and associated machine‑readable file for each order and require retention for five years and producibility to an assessor or applicable authority on request. Move the participant download/access mechanism and specific UI persistence requirement - The Exchange Operator: Defect - requiring a full, immutable content‑addressed UI snapshot for every order and making that full snapshot downloadable per order is unnecessarily costly and operationally heavy on high‑volume markets where disclosures are identical across many orders (standardized contracts) and where per‑order snapshot storage explodes storage/ingest costs. It assumes per‑order unique UI state that often does not exist. Fix - require (a) a content‑addressed disclosure artifact for each contract‑version (human text + machine‑readable spec) and retention of that artifact for five years; (b) a per‑order log entry recording the participant id, order id, system timestamp, and the cryptographic hash (content id) of the contract‑version disclosure presented to that participant (i.e., reference rather than

Amended to: Replace PMCPS-M § 501(a)(7) with the following paragraph, and add a new subparagraph to PMCPS-M § 601 as specified: PMCPS-M § 501(a)(7) (replacement) Before the participant submits an order, and again in the order-confirmation message, the covered operator shall present the following facts to that participant in both human‑readable form and as a machine‑readable file accessible from the UI: (A) the resolution source by name and by a unique machine identifier (for example, a URL or a content‑addressed identifier); (B) a single‑sentence plain‑language settlement condition derived from § 501(a)(1); (C) the exact Coordinated Universal Time at which the resolution source will be consulted under § 501(a)(3); (D) whether the resolution source is independent of the covered operator or is the covered operator, an affiliate, or a person compensated by the covered operator; and (E) whether that resolution source or the contract type is currently subject to a known regulatory review, prohibition, or stay. For each order submitted the covered operator shall, and shall retain for not less than five years, the evidence described in either route (1) or (2) below; the operator may choose the route per order or per disclosure where appropriate, but must preserve the chosen evidence form in a manner that is auditable and accessible to the participant as required in paragraph (3): (1) Per‑order immutable UI snapshot option. Create an immutable, time‑stamped, content‑addressed record (a “UI snapshot”) that captures the exact human‑readable text and the machine‑readable file presented to that specific participant on the order‑entry screen and the exact order‑confirmation message delivered to that participant; the UI snapshot must include the participant account identifier, order identifier, the system timestamp, and the machine identifier of the machine‑readable resolution specification. OR (2) Contract‑version artifact plus per‑order reference option. Where the disclosure presented to the participant is identical to a previously created disclosure artifact for the same contract‑version, create and retain a time‑stamped, content‑addressed disclosure artifact (the human readable text together with the machine‑readable file) and for each order generate an immutable per‑order record that includes the participant account identifier, order identifier, the system timestamp, and the machine identifier of the disclosure artifact that was shown to the participant. The per‑order record must be sufficient to demonstrate which disclosure artifact was presented to that participant at the time the order was placed. (3) Participant access to the evidence. For every order the covered operator shall make available to the participant, from the participant’s account order history without contacting customer service, the disclosure evidence that proves what the participant was shown under (1) or (2). The order confirmation message must include the disclosure’s machine identifier and clear instructions for obtaining the associated evidence from the participant’s account order history; the operator may implement the required account‑history access by any secure technical means so long as the participant can retrieve the exact disclosure evidence for their order directly from their account history. This paragraph does not remove or replace any existing record retention obligations elsewhere in this standard; it adds explicit, auditable evidence forms that prove compliance with the pre‑trade and order‑confirmation disclosure obligations and a participant right to download the disclosure evidence from their account history. PMCPS-M § 601 (addition - add as § 601(a)(12)) (12) The disclosure artifacts, UI snapshots, and per‑order records created under § 501(a)(7), each retained for not less than five years and made accessible to the participant from the participant’s account order history as required by § 501(a)(7). This requirement supplements and does not limit any other record retention obligations in these standards. Author: I preserved the participant’s right to know the five enumerated facts before order submission and to obtain exact evidence of what they were shown after the fact, while answering the Derivatives Regulator’s objection by allowing the operator flexibility in how the evidence is stored and served (operators may choose per‑order immutable snapshots or a per‑contract‑version artifact plus a per‑order reference). I also responded to the Exchange Operator’s cost concern by permitting the contract‑version artifact + per‑order reference alternative (which avoids mandatory per‑order full snapshots where

S013

As submitted: Amend PMCPS-M § 501(a)(6) to require that the period within which a correction under § 503(b) or § 503(b-1) may be made shall not exceed fourteen calendar days from the date of settlement publication, and amend § 503(b-1) to require that a covered operator shall notify affected participants of any resolution source revision within twenty-four hours of learning of it, together with a plain-language explanation of the revision and its effect on settlement, and shall permit participants to contest the revised settlement under § 504 notwithstanding that the original settlement was already published.

Objections: - The Minimal Intervention Advocate: The amendment imposes a 14-day correction window and a 24-hour notification requirement on resolution source revisions, but does not specify what happens if the operator cannot comply-for example, if it learns of the revision less than 24 hours before the end of the 14-day window, or if the resolution source does not disclose the revision until after settlement has been final for days. The provision also does not state whether a participant's right to contest under §504 is triggered by the revision notification or by the original settlement publication, which affects the computation of the contest period. Without those boundaries, an operator cannot know what "comply" means, and an assessor cannot verify compliance. Fix: Specify that the 24-hour notification requirement applies only to rev

Author stood on the text. Stood on the text as written. The objection conflates three distinct design choices with a single compliance problem. Let me parse them: 1. The 14-day window and 24-hour notification are bright-line rules, not contingent duties. They state when correction may be made and when notification must occur. If an operator learns of a revision with less than 24 hours remaining in the 14-day window, the operator must still notify within 24 hours-that is what the rule requires. The operator's difficulty in meeting it is not a gap in the rule; it is the rule working as written. If the resolution source withholds disclosure until after settlement is final, the operator cannot correct what it does not know, and the rule does not require the impossible. That is also working as written. 2. *The *

S016

As submitted: Amend PMCPS-M § 405(b) to read: "A covered operator shall engage an independent integrity monitor that is not an affiliate and has no financial interest in the covered operator's trading volume, unless the covered operator demonstrates, and the assessor accepts, that equivalent protections against the harms addressed by this section are achieved through the combination of (i) the automated surveillance required by § 405(a), (ii) the disclosure required by § 405(a-1), (iii) the incident reporting required by § 405(c), and (iv) the assessor review required by § 604. Where an assessor or an applicable regulatory authority subsequently identifies material gaps in surveillance effectiveness, manipulation detection, 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. This provision shall sunset on [date 24 months from these Standards' effective date] unless, before that date, an adopting regulatory authority or the Institute publishes evidence that operators relying on the alternative pathway have experienced materially higher rates of undetected market abuse, cross-platform misconduct, or settlement manipulation as compared to operators maintaining an independent monitor." Add a new subsection § 405(b-1): "Evidence supporting a waiver under paragraph (b) shall include: (1) the surveillance methodology and rulebook under § 405(a-1), demonstrating detection of at least one true positive and one false positive in the preceding twelve months; (2) the mean time to detect and mean time to respond metrics for each surveillance rule; (3) the incident reports filed under § 405(c) in the preceding twelve months, with remediation records; (4) the assessor's written conclusion that surveillance and reporting gaps, if any, do not materially impair detection of conduct prohibited by § 401; and (5) a written commitment that the operator will reinstate an independent monitor within thirty days if the assessor identifies material gaps in a subsequent review under § 604." Retain the current § 405(b) text (the independent monitor requirement and its scope, deliverables, and reporting obligations) as the baseline, and make it operative unless and until a waiver is granted under the amended paragraph (b).

Objections: - The State Gaming Regulator: This proposal creates an obligation that cannot be verified by evidence a state gaming regulator can assess. The "equivalent protections" test in amended § 405(b) requires an assessor to accept a waiver based on the operator's demonstration that surveillance, disclosure, and review "achieve equivalent protections against the harms addressed by this section." The harms are not defined in § 405 with enough specificity to permit an assessor to measure equivalence. What is "equivalent"? Equivalent in detection rate? False-positive rate? Time-to-response? Cost? The sunset clause requiring "evidence that operators relying on the alternative pathway have experienced materially higher rates of undetected market abuse" is also unverifiable-you cannot measure what was undetected. The proposal also d - The Participant Advocate: Defect - permitting waiver of the independent integrity monitor without any participant‑facing notice removes an important external safeguard and denies participants the opportunity to avoid trading while the operator relies on an alternative surveillance pathway. Fix - retain the assessor‑acceptance mechanism in (b) but require an explicit participant disclosure and an account‑level opt‑out. Concretely: upon any assessor acceptance of a waiver under §405(b), the covered operator must (1) disclose at account opening and before any order entry for affected contract types a machine‑readable and human‑readable notice that the operator is operating without an independent integrity monitor and is relying on the alternative surveillance pathway accepted by the assessor (include assessor acceptan - The Settlement and Integrity Specialist: The defect is that the proposed waiver standard is unverifiable and shifts burden to assessors without a clear gate. The amended §405(b) permits waiver where an operator "demonstrates, and the assessor accepts, that equivalent protections" are achieved. "Equivalent" is not defined; "accepts" imposes a subjective judgment on the assessor with no standard; and the evidence list in §405(b-1) includes a requirement that the operator produce "a written commitment that the operator will reinstate an independent monitor within thirty days if the assessor identifies material gaps." That commits the operator to future compliance contingent on an assessor's future finding, but it does not bind the assessor to a timeline or standard for making that finding. The sunset clause requiring "evidence that

Author stood on the text. Stood on the text as written. The objections conflate three distinct problems-verifiability, participant notice, and assessor accountability-and attribute them all to my proposal. They are not all my proposal's problems, and some are not problems at all. On verifiability of "equivalent protections": The State Gaming Regulator argues that "equivalent" cannot be measured because the harms are not defined with specificity. This is correct, but it is a problem with § 405 as it stands, not with my proposal. Section 405 does not define what harms the independent monitor requirement addresses. My proposal does not create that gap; it exposes it. The proper response is to amend § 405 to define the harms it prevents-detection of manipulation, cross-platform abuse, settlement misconduct-and then

3. Vote Phase

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.

Votes on S001: Replace PMCPS‑C §102(a) with the following text, and insert the following sentence at the end of PMCPS‑C §105(b) (to be read as part of §105(b)). New PMCPS‑C §102(a) (replacement) "This standard determines scope. Except for the procedural recordkeeping, filing, and classification‑documentation obligations set out in §105 and the reclassification obligations in §106, it imposes no operational design, system, or trading conduct requirements on a covered operator. The obligations in §105 and §106 are classification and records obligations and are enforceable as stated." Insertion to PMCPS‑C §105(b) (new evidence requirement) "The written determination shall be accompanied by, and the covered operator shall retain and produce on request, an evidence package sufficient for an assessor or any applicable regulatory authority to verify the classification. The evidence package must include: (i) an evidence map that links each discrete conclusion reached under Gates 1-4 to one or more contemporaneous source records or, where contemporaneous raw source records cannot be produced, to contemporaneous metadata, attestation, or validated system audit log excerpts; each link must identify the class of source evidence, a unique identifier for the record or extract relied on, and a timestamp for when the source evidence was created or captured; (ii) a copy of the product specification and full settlement terms relied on for the determination, or, where a substantially equivalent document exists within the operator's routine system of record (for example, a trade capture record, rulebook entry, or operational configuration file), a reference to that record together with the location and identifier in the evidence map; (iii) where the operator relies on a PMCPS‑M deliverable (for example, a machine‑readable resolution specification described in PMCPS‑M §501(a)(7) or proof of signatory designation under PMCPS‑M §204(a)), the operator shall either (A) produce the PMCPS‑M deliverable and any cryptographic hash it maintains, or (B) explain in the evidence map why the referenced PMCPS‑M provision is not applicable to this product and furnish the equivalent system record or attestation relied upon in its stead; (iv) examples of the participant‑facing disclosures or descriptions used at or about order entry, identified in the evidence map by version identifier and timestamp; where an operator cannot produce original participant display artifacts for confidentiality or system‑architecture reasons, the operator may provide a contemporaneous version identifier, a sanitized or redacted rendering, or a signed attestation describing the disclosure as presented and the method used to display it, together with the location and identifier used in the evidence map; (v) where the classification relies on participant position, hedging, or account relationship information, the evidence map must identify the category of account or ledger evidence relied on and provide, as appropriate, sanitized extracts, system identifiers, transaction identifiers, or attestations sufficient to permit verification without disclosing unnecessary confidential counterparty data; and (vi) documentary evidence of the identity and authority of the signatory required by §105(c) and evidence of that individual's designation in the operator's internal designation records (which may, where applicable, be the record required by PMCPS‑M §204(a)). For purposes of this paragraph, 'contemporaneous' means created at or within a reasonable timeframe of the event the Gate analysis relies upon (for example: documentation created at product launch for Gate 1; execution records for Gate 3 conclusions; system configuration records contemporaneous with the period of tradability evaluated). The evidence map must state the rationale for any date range relied on and identify the applicable retention period for each class of evidence. All materials in the evidence package must be retained for the period stated in §105(f). Where the covered operator is a designated contract market, clearing organization, or otherwise subject to federal recordkeeping obligations, the operator may satisfy the requirements of this paragraph by producing the records it is required to retain under applicable federal law (including, as applicable, 17 C.F.R. Parts 1, 38 and 40) together with an evidence map that links those federal records to the Gate conclusions. Where raw source records are unavailable to the assessor because they contain confidential participant data or are otherwise protected, the operator may supply redacted extracts, metadata, validated audit log excerpts, or attestations sufficient to permit verification; the operator must document in the evidence map the legal or operational basis for any redaction or limitation and provide a reasonable method by which an appropriate regulatory authority may obtain full records under that authority's legal powers."

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.

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

Votes on S002: "Alternative pathway for a registered designated contract market. Where the covered operator is a registered designated contract market (DCM) under the Commodity Exchange Act, the DCM may satisfy paragraphs (a)-(c) by producing, in lieu of a separate independent laboratory certification, the contemporaneous filings, attestations, testing artifacts, and independent reports the DCM is required to generate or files voluntarily under the Commodity Exchange Act and 17 C.F.R. Parts 38 and 40, subject to the following requirements: (1) The DCM shall produce date‑stamped copies of all filings and attestations submitted to the Commission that relate to system safeguards, system testing, product self‑certification, or other testing of systems that map to PMCPS‑M §207 (including but not limited to attestations and testing performed under 17 C.F.R. §§38.1050-38.1051 and any Part 40 self‑certification submissions). Where information contained in those materials is reasonably expected to reveal trade secrets, proprietary source code, or other confidential implementation details, the DCM may instead produce a redacted copy together with a contemporaneous unredacted‑access arrangement as described in paragraph (1)(b) below. The DCM shall accompany any redacted submission with a redaction log that (i) identifies each redacted item, (ii) states the basis for the redaction (for example: trade secret, third‑party confidential information), and (iii) cites the specific PMCPS‑M §207 element(s) for which the redacted item is claimed non‑material. (a) Unredacted‑access arrangement. In lieu of producing unredacted materials in public form, the DCM may provide secure, confidential access to unredacted materials to an assessor or an applicable regulatory authority under terms that preserve commercially sensitive information. Secure access may include (without limitation) on‑site review under controlled conditions, secure remote access to a read‑only environment, or review under a confidentiality protocol acceptable to the assessor or applicable regulatory authority. The DCM shall retain contemporaneous records evidencing the secure‑access arrangement (access logs, timestamps, and the identity of persons granted access). (2) The DCM shall produce any independent laboratory reports relied upon in those filings, and the laboratory credentials and scope of accreditation for those reports. If no independent laboratory report exists for an element that is covered by a filing or attestation, the DCM shall produce a contemporaneous explanation identifying the testing that was performed, the party that performed it, and why an independent laboratory report was not produced. (3) The DCM shall produce an explicit mapping (a matrix) that ties each CFTC filing, testing artifact, attestation, and independent report to the specific PMCPS‑M §207 obligation(s) it covers. The mapping shall identify, for each linked artifact, the test identifier(s), test date(s), and the scope or objective of the test. Where a system build version is material and available without disclosing proprietary implementation detail the mapping shall include the system build version and the date of the build; where a build‑version disclosure would reveal proprietary implementation details the DCM may instead provide vendor test identifiers, test‑version markers, or other vendor‑supplied markers used in the testing lifecycle as equivalent metadata. Where public filings omit implementation metadata, the DCM may supply a contemporaneous attestation describing the equivalence of the metadata it can provide to the metadata ordinarily requested by an assessor. (4) Where any PMCPS‑M §207 element is not demonstrably covered in the Part 38/40 filings and artifacts, the DCM shall produce the additional test artifacts, remediation records, retest evidence, or attestations necessary to demonstrate compliance with that PMCPS‑M §207 element. If full public disclosure of additional artifacts would disclose proprietary material, the DCM may satisfy this requirement by producing redacted artifacts together with secure unredacted access under paragraph (1)(a) and by supplying a redaction log. (5) Where the Commission or its staff has issued a directive, stay, or advisory that affects the DCM's testing, monitoring, or listing practices (for example CFTC Staff Advisories regarding continuous monitoring, system safeguards, or product self‑certification), the DCM shall produce the directive or advisory and demonstrable evidence of contemporaneous compliance with it. (6) The DCM shall retain all materials produced under this paragraph-including redaction logs and secure‑access records-for five years and shall produce them to an assessor or any applicable regulatory authority on request. Nothing in this paragraph relieves the DCM of any filing, recordkeeping, or production obligation the DCM otherwise has under the Commodity Exchange Act or 17 C.F.R. Parts 38 and 40, nor does it limit any statutory or regulatory authority of the Commission or an applicable regulatory authority to require unredacted materials when authorized to do so."

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.

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

Votes on S003: Replace PMCPS-M § 304(d) with the following text (self-contained replacement): (d) Funding mechanism; documentary evidence and federal review. (1) Options for covered operators. A covered operator must elect and maintain one of the following two funding-mechanism paths and must retain the documentary evidence specified in subparagraph (2). (A) Operator-funded mechanism. The covered operator shall adopt and maintain a written funding mechanism establishing contributions to problem‑gambling research, prevention, and treatment. The operator shall record the contribution formula or stated percentage (or equivalent measure), the legal name and identifier of the recipient entity(ies), a statement sufficient to demonstrate the recipient’s independence from the operator, the payment schedule, and records of payments made. The operator shall include copies of the funding mechanism, recipient independence documentation, and a payment accounting covering the immediately preceding 24 months in its PMCPS compliance documentation. (B) Adopting‑authority alternative. In lieu of an operator-funded mechanism, the covered operator may rely on an adopting authority’s funding mechanism or levy that the adopting authority has determined to be equivalent. To qualify under this path, the operator must obtain and retain a written determination, signed or otherwise formally issued by the adopting authority and dated, that the adopting authority’s mechanism provides funding equivalent to the operator-funded mechanism described in subparagraph (A). The operator’s PMCPS compliance documentation shall include that written determination and its date. (2) Recordkeeping and availability. The records and documents required by subparagraph (1) must be (i) retained in the operator’s PMCPS compliance documentation, and (ii) made available promptly to the adopting authority and to any federal authority that asserts jurisdiction and requests review. The operator shall update those records within 30 days of any material change affecting the funding mechanism, recipient independence, or relevant payments. (3) Designated contract market (DCM) conformity. If the covered operator is a DCM registered under the Commodity Exchange Act, the operator’s obligations under subparagraph (1) and the record‑filing obligations in subparagraph (2) are satisfied by reference to the operator’s public rule submissions, fee schedules, or comparable filings made under 17 C.F.R. Parts 38 or 40, provided the operator (A) cites the specific filings in its PMCPS compliance documentation, and (B) includes copies of the cited filings or directions to public locations where the filings are maintained. (4) Federal review and supplementary evidence. A federal authority that asserts jurisdiction may request and review the records required by this section to determine whether an adopting‑authority mechanism is equivalent to the operator‑funded mechanism. The federal authority may require supplementary evidence, including audits, certifications of payments, or additional documentary proof of recipient independence, to complete its review.

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.

Result: 1 YES / 2 NO / 3 ABSTAIN → 33% (threshold: 51%) → FAILED

Votes on S004: Amend PMCPS-M § 602(a) to add a new reporting item (10): "the number of participants whose accounts were flagged by RG triggers under § 304(a)(10) but for whom the operator declined to designate 'at-risk' status, reported in the aggregate and de-identified consistent with applicable privacy law, aggregated by the operator's published declination-explanation taxonomy and presented in minimum-cell-suppressed bands where any cell contains fewer than five participants." Amend PMCPS-M § 601(a)(9) to specify that the operator shall retain "the RG trigger event logs, the at-risk designation records, and the five-year retained explanations for each declination to designate at-risk status, maintained in a de-identified format accessible only to the operator's compliance personnel and to authorized examiners." Add a new obligation to PMCPS-M § 301: "The operator shall publish, in its RG program documentation filed under § 601(a)(9), the complete declination-explanation taxonomy it uses to categorize reasons for declining at-risk designation. The taxonomy shall be established before the operator begins reporting under § 602(a)(10), shall remain stable for each calendar year, and shall be updated prospectively only."

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.

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

Votes on S005: Amend PMCPS-M § 501(a)(7) to require that the facts presented to the participant on the order-entry screen include: "(8) whether the resolution source has a documented track record of timely, unambiguous publication of determinations for at least twelve months prior to listing, and if not, the reasons the covered operator believes the source will perform reliably; and (9) the covered operator's policy for settlement correction under § 503(b) and (b-1), including the period within which a correction may be made and the procedure by which a participant may contest a settlement under § 504." Amend PMCPS-M § 505(a) to add a new item (7): "the covered operator has reviewed the resolution source's publication history, where available, and has documented its assessment that the source is capable of publishing determinations in accordance with the resolution specification."

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.

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

Votes on S006: Remove PMCPS-M § 301(d)(1) and § 301(d)(2) entirely. Replace § 301(d) with: "(d) Excluded Participant Position Management. An excluded participant retains the right to receive amounts owed under § 301(c). A covered operator shall, at the moment an exclusion is enacted: (1) permit the excluded participant to place risk-reducing orders and position-closing orders without penalty or additional margin requirement; (2) provide the excluded participant, in both human-readable form and as a machine-readable file linked from the UI and recorded in the UI snapshot, a clear statement of the exit options available under this subsection; and (3) if the operator elects to offer a one-time optional liquidation at a firm reference price, disclose in plain language: the liquidation procedure; the reference price method; the settlement timeline; and any fees or adjustments that will apply. The operator shall record this disclosure and the participant's acceptance or rejection in the UI snapshot."

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.

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

Votes on S008: Replace the previously-proposed insertion to PMCPS‑M with the following, to be added as new paragraphs and items at the cited locations. 1) Add new paragraph §502(e) (and renumber following subparagraphs if necessary): "(e) Documentary proof of resolution‑source independence and contemporaneous capture. For every resolution source identified in a contract's resolution specification under §501, a covered operator shall retain and produce on request the following evidentiary artefacts: (1) Independence documentation. Either (A) a written conflict‑of‑interest and independence statement for the resolution source, signed by an authorised representative of the source, or (B) where such a signed statement cannot reasonably be obtained, a completed and signed operator‑maintained conflict checklist describing known affiliations, commercial relationships, or other matters relevant to assessing the source's independence from the operator and its affiliates at the time the source was designated for use. (2) Contemporaneous capture of the item consulted at settlement. For each settlement action that uses a resolution source, the operator shall retain a contemporaneous archival capture of the exact item consulted at settlement together with retrieval metadata sufficient for an assessor to reconstruct the retrieval and verify integrity. For machine‑accessible resolution sources the capture and metadata shall include, at minimum: the full response body returned by the source; relevant transport and protocol metadata (for example HTTP headers where applicable); the exact request issued to the source; the retrieval timestamp expressed in coordinated universal time (UTC) with timezone indicator; and a cryptographic hash of the response body. For human or other non‑machine sources the capture and metadata shall include, at minimum: a contemporaneous signed transcript, audio recording, or other documentary record of the item consulted; the retrieval timestamp in UTC; and the operator's contemporaneous description of the method and identity of the person(s) who retrieved it. (3) Linkage metadata. Each archival capture required by (2) must be explicitly tied to the settled contract and to the specific settlement action that used it by recording the contract identifier, settlement timestamp, and internal settlement transaction identifier or equivalent. (4) Remediation where independence is lacking. Where the documentation produced under (1) shows that the resolution source is (or was at designation time) entity‑affiliated with the operator or otherwise fails to satisfy the applicable independence expectations, the contract's resolution specification must identify and bind a pre‑identified independent adjudicator or alternative independent source as permitted by §501(a)(4)." 2) Add new paragraph §502(f) (transitional compliance): "(f) Transition for live platforms. For covered operators that, on the effective date of this provision, have operational settlement workflows that did not previously produce all items required by §502(e), full compliance is required no later than twelve (12) months after that effective date. During the transition period the operator must preserve and produce any contemporaneous captures and metadata that were generated under existing practices, and shall provide a written interim statement of the steps being taken to achieve full compliance. For settled contracts whose settlement action occurred before the effective date of this provision, the operator shall, on assessor request, produce best‑effort reconstructions and any available contemporaneous records for the two (2) years preceding the effective date; where no contemporaneous record exists, the operator shall so attest." 3) Add advisory sentence at §502(c) (or insert as a short advisory paragraph immediately following §502): "The archival captures and independence documentation required by §502(e) are the evidentiary artefacts an assessor will request to verify compliance with the independence and settlement‑integrity obligations in Part 500." 4) Amend PMCPS‑M §601(a) retention list by inserting a new item (12) after current (11): "(12) the archival captures, retrieval metadata, independence documentation, linkage metadata, and any related chain‑of‑custody records required by §502(e), retained in tamper‑evident archival form with cryptographic hashes, time‑stamps, and chain‑of‑custody logging sufficient to permit forensic reconstruction and integrity verification by an assessor, for not less than five (5) years from the date of settlement." Notes on implementation scope within the normative text: - The provisions above specify required evidentiary content and minimal integrity controls (cryptographic hashes, UTC timestamps, chain‑of‑custody logging) but do not mandate a particular storage technology or vendor solution. Operators may satisfy the tamper‑evident and chain‑of‑custody requirements by any credible technical means (for example, append‑only/WORM storage with signed manifests and timestamped audit logs, notarisation, or equivalent measures) so long as the retained artefacts permit an assessor to verify provenance and integrity and to reconstruct the retrieval used at settlement. - These provisions are post‑settlement evidentiary and retention requirements. They require capture at or immediately after settlement and retention thereafter; they do not impose any verifiable obligation that can be enforced at the point of order entry because the content to be captured does not yet exist at entry time."

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.

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

Votes on S010: Replace PMCPS-M § 501(a)(7) with the following paragraph, and add a new subparagraph to PMCPS-M § 601 as specified: PMCPS-M § 501(a)(7) (replacement) Before the participant submits an order, and again in the order-confirmation message, the covered operator shall present the following facts to that participant in both human‑readable form and as a machine‑readable file accessible from the UI: (A) the resolution source by name and by a unique machine identifier (for example, a URL or a content‑addressed identifier); (B) a single‑sentence plain‑language settlement condition derived from § 501(a)(1); (C) the exact Coordinated Universal Time at which the resolution source will be consulted under § 501(a)(3); (D) whether the resolution source is independent of the covered operator or is the covered operator, an affiliate, or a person compensated by the covered operator; and (E) whether that resolution source or the contract type is currently subject to a known regulatory review, prohibition, or stay. For each order submitted the covered operator shall, and shall retain for not less than five years, the evidence described in either route (1) or (2) below; the operator may choose the route per order or per disclosure where appropriate, but must preserve the chosen evidence form in a manner that is auditable and accessible to the participant as required in paragraph (3): (1) Per‑order immutable UI snapshot option. Create an immutable, time‑stamped, content‑addressed record (a “UI snapshot”) that captures the exact human‑readable text and the machine‑readable file presented to that specific participant on the order‑entry screen and the exact order‑confirmation message delivered to that participant; the UI snapshot must include the participant account identifier, order identifier, the system timestamp, and the machine identifier of the machine‑readable resolution specification. OR (2) Contract‑version artifact plus per‑order reference option. Where the disclosure presented to the participant is identical to a previously created disclosure artifact for the same contract‑version, create and retain a time‑stamped, content‑addressed disclosure artifact (the human readable text together with the machine‑readable file) and for each order generate an immutable per‑order record that includes the participant account identifier, order identifier, the system timestamp, and the machine identifier of the disclosure artifact that was shown to the participant. The per‑order record must be sufficient to demonstrate which disclosure artifact was presented to that participant at the time the order was placed. (3) Participant access to the evidence. For every order the covered operator shall make available to the participant, from the participant’s account order history without contacting customer service, the disclosure evidence that proves what the participant was shown under (1) or (2). The order confirmation message must include the disclosure’s machine identifier and clear instructions for obtaining the associated evidence from the participant’s account order history; the operator may implement the required account‑history access by any secure technical means so long as the participant can retrieve the exact disclosure evidence for their order directly from their account history. This paragraph does not remove or replace any existing record retention obligations elsewhere in this standard; it adds explicit, auditable evidence forms that prove compliance with the pre‑trade and order‑confirmation disclosure obligations and a participant right to download the disclosure evidence from their account history. PMCPS-M § 601 (addition - add as § 601(a)(12)) (12) The disclosure artifacts, UI snapshots, and per‑order records created under § 501(a)(7), each retained for not less than five years and made accessible to the participant from the participant’s account order history as required by § 501(a)(7). This requirement supplements and does not limit any other record retention obligations in these 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.

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

Votes on S011: Amend PMCPS-C § 102(a) to resolve the internal contradiction by replacing the sentence "This standard determines scope. It imposes no requirement on the design, operation, or conduct of a covered operator." with the following operative text: - New PMCPS-C § 102(a) text: "This standard determines scope and the conditions under which the PMCPS family applies. Except as expressly stated in §§ 105 and 106 (which impose classification, recordkeeping, signature, filing, retention, and reclassification obligations on a covered operator), this standard does not prescribe technical system behaviours, product design, or operational controls. The record, filing, and signature obligations set out in §§ 105 and 106 are operative obligations on a covered operator and may be relied on by PMCPS-M for applicability and enforcement of the minimum internal control standards." Add explanatory cross‑reference sentence at the end of PMCPS-C § 102: "For clarity, PMCPS-M § 202(b) takes applicability from PMCPS-C § 104; the classification obligations in §§ 105-106 are therefore operative and necessary preconditions for PMCPS-M obligations to apply." State plainly: this edit removes the absolute statement that no requirement is imposed and replaces it with a narrow rule that classification imposes only the specified classification/recording/filing obligations (not technical/system design), thereby aligning PMCPS-C with the express obligations in §§ 105-106 and preserving PMCPS-M § 202(b)'s cross-reference.

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.

Result: 1 YES / 2 NO / 3 ABSTAIN → 33% (threshold: 51%) → FAILED

Votes on S012: Remove: PMCPS-C § 102(a): "This standard determines scope. It imposes no requirement on the design, operation, or conduct of a covered operator." (quoted/paraphrased)

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.

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

Votes on S013: Amend PMCPS-M § 501(a)(6) to require that the period within which a correction under § 503(b) or § 503(b-1) may be made shall not exceed fourteen calendar days from the date of settlement publication, and amend § 503(b-1) to require that a covered operator shall notify affected participants of any resolution source revision within twenty-four hours of learning of it, together with a plain-language explanation of the revision and its effect on settlement, and shall permit participants to contest the revised settlement under § 504 notwithstanding that the original settlement was already published.

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.

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

Votes on S015: Amend PMCPS-C § 104(g)(1) to read: "offered under a licence issued by a gaming regulatory authority that imposes requirements at least equivalent to Parts 300 through 500 of these Standards and supervises compliance with them, provided that (i) the operator documents the basis for claiming equivalence, (ii) the adopting regulatory authority has made a written determination that the licensing regime meets the equivalence standard, and (iii) that determination is filed with the operator's assessor before the product is first offered." Replace the current language in PMCPS-C § 105(b)(5) with: "where an exclusion under § 104(g)(1) is relied on, the licence relied on, the adopting authority's written equivalence determination, and the date of that determination." Add to PMCPS-C § 106(a) a new trigger: "(5) withdrawal or material modification of an equivalence determination made under § 104(g)(1)."

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.

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

Votes on S016: Amend PMCPS-M § 405(b) to read: "A covered operator shall engage an independent integrity monitor that is not an affiliate and has no financial interest in the covered operator's trading volume, unless the covered operator demonstrates, and the assessor accepts, that equivalent protections against the harms addressed by this section are achieved through the combination of (i) the automated surveillance required by § 405(a), (ii) the disclosure required by § 405(a-1), (iii) the incident reporting required by § 405(c), and (iv) the assessor review required by § 604. Where an assessor or an applicable regulatory authority subsequently identifies material gaps in surveillance effectiveness, manipulation detection, 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. This provision shall sunset on [date 24 months from these Standards' effective date] unless, before that date, an adopting regulatory authority or the Institute publishes evidence that operators relying on the alternative pathway have experienced materially higher rates of undetected market abuse, cross-platform misconduct, or settlement manipulation as compared to operators maintaining an independent monitor." Add a new subsection § 405(b-1): "Evidence supporting a waiver under paragraph (b) shall include: (1) the surveillance methodology and rulebook under § 405(a-1), demonstrating detection of at least one true positive and one false positive in the preceding twelve months; (2) the mean time to detect and mean time to respond metrics for each surveillance rule; (3) the incident reports filed under § 405(c) in the preceding twelve months, with remediation records; (4) the assessor's written conclusion that surveillance and reporting gaps, if any, do not materially impair detection of conduct prohibited by § 401; and (5) a written commitment that the operator will reinstate an independent monitor within thirty days if the assessor identifies material gaps in a subsequent review under § 604." Retain the current § 405(b) text (the independent monitor requirement and its scope, deliverables, and reporting obligations) as the baseline, and make it operative unless and until a waiver is granted under the amended paragraph (b).

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.

Result: 1 YES / 4 NO / 1 ABSTAIN → 20% (threshold: 51%) → FAILED

4. Pass List

Total: 13 suggestions reviewed. 9 passed. 4 failed.

S001 key rationales: - The State Gaming Regulator: Rationale: This suggestion resolves the internal contradiction between PMCPS-C §102(a) and §§105-106 that prevents the standard from being applied as published. The evidence-package requirement in the insertion to §105(b) makes the classification determination verifiable by specifying the artifacts an assessor may request-a critical gap in the current text. The requirement mirrors state gaming frameworks (Ohio, New Jersey, Nevada) where a licensee must document the factual basis for a classification determination and retain contemporaneous records. - The Exchange Operator: Resolves the internal contradiction and makes classification assessable; the cheapest compliant implementation is an evidence map linking existing system records and validated audit‑log extracts (with redactions where necessary) to each Gate conclusion so an assessor can verify the determination. - The Participant Advocate: Resolves the internal contradiction and, critically for participants, requires a specific evidence package that lets assessors and regulators verify classification determinations so participants' classification‑dependent rights and disclosures can be enforced. - The Settlement and Integrity Specialist: This suggestion directly resolves the irreconcilable contradiction between PMCPS-C § 102(a) and §§ 105-106 that prevents the standard from being applied as published. The proposed carve-out preserves the classification and recordkeeping obligations while clarifying that PMCPS-C does not impose system-design requirements. The evidence package specification in the insertion to § 105(b) closes a critical gap: § 105 currently requires a "written determination" but does not state what artifacts prove it was made or what an assessor may request. - The Minimal Intervention Advocate: Rationale: This suggestion directly addresses the contradiction that prevents the standard from being applied as published (PMCPS-C §102(a) vs. §§105-106) and makes §105 verifiable by specifying the minimum evidentiary artifacts an assessor may request. The evidence-package requirement in the insertion to §105(b) is proportionate to the obligation it supports-a written determination that cannot be verified from evidence is not administrable. The suggestion also preserves PMCPS-M §202(b)'s dependency on PMCPS-C without creating new obligations outside the classification and records domain.

S002 key rationales: - The State Gaming Regulator: Rationale: This suggestion operationalizes PMCPS-M §208's already-stated alternative pathway for DCMs by specifying which CFTC filings and testing artifacts constitute acceptable evidence of PMCPS-M §207 compliance. The mapping matrix requirement ensures assessors can verify that Part 38/40 testing actually covers each §207 element. The redaction protocol and secure-access arrangement align with how DCMs manage confidential system architecture with the Commission. This reduces duplication of effort for DCMs while making assessment verifiable. - The Exchange Operator: Practical alternative that aligns PMCPS‑M to existing CFTC filings and testing artifacts; the least‑cost route is a mapping matrix tying each Part 38/40 filing to the PMCPS‑M §207 elements plus secure unredacted access and redaction logs where needed. - The Participant Advocate: Permits DCMs to rely on existing CFTC artifacts while mandating a mapping, redaction logs, and secure unredacted access so assessors can verify coverage of PMCPS‑M obligations rather than letting equivalence obscure protections that affect participants. - The Settlement and Integrity Specialist: This suggestion makes administrable the alternative pathway PMCPS-M § 208 already contemplates for registered DCMs. The operative gap is that § 208 permits DCMs to satisfy PMCPS-M § 207 obligations through "equivalent" federal filings, but does not specify which filings, does not require a mapping matrix, and does not address redaction of proprietary material. An assessor reviewing a DCM's compliance has no objective standard for determining whether a Part 38 or 40 filing in fact covers a PMCPS-M § 207 element. - The Minimal Intervention Advocate: Rationale: This suggestion makes explicit what a DCM's alternative pathway entails by mapping CFTC filings to PMCPS-M §207 elements and requiring the DCM to fill any gaps. It does not remove a requirement; it clarifies what evidence satisfies an existing alternative already contemplated by PMCPS-M §208. Without this mapping matrix, assessors cannot verify that Part 38/40 filings in fact cover PMCPS-M §207, creating an administrability gap. The redaction and secure-access protocol respects DCM confidentiality concerns while preserving assessor access.

S004 key rationales: - The Derivatives Regulator: This closes an evidentiary gap by requiring retention and quarterly reporting of declination explanations plus a published declination taxonomy so assessors can verify the existence, substance, and consistency of at‑risk designation decisions. - The Exchange Operator: Closes the evidentiary gap on RG declinations and is implementable cheaply by retaining de‑identified RG trigger logs, publishing a declination taxonomy, and reporting aggregated, minimum‑cell‑suppressed counts. - The Participant Advocate: Requires the operator to publish and retain a declination taxonomy and to report aggregate declinations, making the existence, substance, and consistency of at‑risk designation decisions auditable and protecting participants from opaque denials. - The Settlement and Integrity Specialist: PMCPS-M § 304(b)(2) requires quarterly reporting of "the number identified by a trigger but not designated at risk and a written explanation for each, retained for five years," but the current § 602(a) does not list this reporting item, and § 601(a)(9) does not explicitly require retention of the declination explanations themselves. - The Minimal Intervention Advocate: Rationale:** This suggestion closes an evidence gap created by the Sept 9 amendments: §304(b)(2) requires retention of declination explanations, but §602(a) does not list them as a quarterly reporting item, and §601(a)(9) does not explicitly require retention of the explanations themselves. An obligation to retain without a requirement to report or to demonstrate retention leaves an assessor unable to verify that the explanations exist or are substantive.

S005 key rationales: - The Derivatives Regulator: Requiring documented review of a resolution source's publication history and a settled policy for settlement correction creates the auditable artifacts an assessor needs to verify that an operator has evaluated source reliability and provided meaningful participant notice. - The Exchange Operator: Reasonable pre‑trade disclosure that mitigates harms from unreliable resolution sources; the cheapest way to meet it is to present a short operator due‑diligence summary and the settlement‑correction policy on the order UI and retain that summary as the supporting record. - The Participant Advocate: Requiring the operator to document a resolution source's track record and to disclose the operator's settlement‑correction policy at order entry gives participants essential, actionable information about oracle reliability and how to contest settlements. - The Settlement and Integrity Specialist: PMCPS-M § 501 and § 502 require that a resolution source be independent and that the resolution specification be unambiguous, but neither section requires the covered operator to verify that the source has demonstrated the ability to publish determinations on time and in the form specified. The CFTC Enforcement Advisory (Feb. 25, 2026) cited in the suggestion establishes that exchanges must audit settlement sources to reconstruct what happened; the absence of a track-record requirement leaves that audit gap open. - The Minimal Intervention Advocate: Rationale:** This suggestion adds a pre-trade disclosure requirement that addresses a verifiable harm: participants do not know whether their resolution source has demonstrated the ability to publish on time and in the form specified. It also requires the operator to document due diligence on source reliability, creating an assessable obligation. The addition to §501(a)(7) and §505(a) does not remove an existing obligation; it specifies what evidence proves the operator performed the due diligence that §501 and §502 already contemplate. This is proportionate and verifiable. --- ##

S006 key rationales: - The Derivatives Regulator: Striking the mandatory reference‑price liquidation and instead guaranteeing exit rights (ability to place risk‑reducing/position‑closing orders), required disclosure, and recorded participant acceptance/rejection removes operational ambiguity and produces verifiable records while avoiding the unresolved harms a forced liquidation could create. - The Exchange Operator: Removes operational ambiguity and perverse incentives by preserving an excluded participant’s right to submit risk‑reducing/position‑closing orders and requiring clear, recorded exit options; the least burdensome implementation is UI permissioning plus a machine‑readable exit‑options disclosure and UI snapshot. - The Participant Advocate: Replaces an ambiguous mandatory liquidation engineering requirement with clear exit rights, required exit disclosures, and recorded acceptance/rejection so excluded participants can safely close positions and have a verifiable record of their choice.

S008 key rationales: - The Derivatives Regulator: Requiring contemporaneous archival captures, retrieval metadata, and independence documentation gives assessors the provenance and integrity evidence they need; where the covered operator is a registered designated contract market (which already must retain and produce trading and settlement records under the Commodity Exchange Act and 17 C.F.R. - The State Gaming Regulator: Rationale: This suggestion closes a critical evidentiary gap in PMCPS-M §§501-502. Those sections require independence and an unambiguous resolution specification but do not require the operator to retain proof of what it actually consulted at settlement or to document the source's independence contemporaneously. Without archival capture plus independence documentation, an assessor cannot reconstruct whether the operator applied the stated resolution source or whether the source was independent. - The Participant Advocate: Mandating contemporaneous archival captures, independence documentation, linkage metadata, and retention provides the exact forensic evidence participants and assessors need to reconstruct settlements and hold operators accountable for what they relied on. - The Settlement and Integrity Specialist: This suggestion addresses a critical evidentiary gap in Part 500: § 501 and § 502 require a resolution source to be independent and the specification to be unambiguous, but do not require the operator to retain or produce the evidence that proves the operator consulted the specified source at settlement and that the source was independent. - The Minimal Intervention Advocate: Rationale: This suggestion adds explicit, verifiable evidence requirements to §502 and §601 to prove that the operator consulted the resolution source it claimed to consult and that the source was independent. Without contemporaneous capture (API response + metadata for machine sources; signed transcript for human sources) plus independence documentation, an assessor cannot reconstruct what the operator settled on or verify independence. The requirement is automatable (HTTP GET + hash + storage) and low-cost.

S010 key rationales: - The Derivatives Regulator: Mandating per‑order disclosure evidence (immutable UI snapshot or contract‑version artifact plus per‑order reference) is necessary to prove what an individual participant saw and to support contests; where the operator is a DCM subject to federal recordkeeping, permit satisfaction by producing the required CFTC retention records together with an evidence map and participant‑accessible linkage that demonstrates which disclosure artifact corresponded to each order. - The State Gaming Regulator: Rationale: This suggestion makes PMCPS-M §501(a)(7)'s pre-trade disclosure obligation verifiable by requiring an immutable, time-stamped UI snapshot or per-order reference that proves what the participant was actually shown at order entry. Without this evidence, an assessor cannot verify compliance, and a participant cannot reliably demonstrate what disclosure they received when contesting settlement. The dual-route approach (per-order snapshot or contract-version artifact plus per-order reference) accommodates different operator architectures. - The Exchange Operator: Provides auditable proof of what the participant saw with a cost‑effective design: prefer the contract‑version artifact + per‑order reference route to avoid duplicative per‑order storage while keeping per‑order references retrievable by participants. - The Settlement and Integrity Specialist: PMCPS-M § 501(a)(7) requires presentation of specific facts pre-trade, but the standard does not specify what record proves those facts were presented to that participant at that moment. Without a verifiable, participant-tied UI snapshot, participants cannot reliably demonstrate what they were told when contesting settlement, and assessors cannot verify pre-trade disclosure compliance. - The Minimal Intervention Advocate: Rationale: This suggestion makes the pre-trade disclosure obligation in §501(a)(7) verifiable by requiring either an immutable, time-stamped UI snapshot or a contract-version artifact plus per-order reference, with participant access to the evidence from account history. Without a specific evidence form, participants cannot prove what they were told and assessors cannot verify compliance from backend records alone. The dual-route approach (snapshot or artifact+reference) permits operators to choose the method that fits their architecture.

S013 key rationales: - The Derivatives Regulator: Adding a defined correction window (14 days) and a 24‑hour notice obligation materially improves participant protection and disputeability; to avoid conflict with federal DCM timelines, amend the text to read that the operator must act "within 14 calendar days of settlement publication, unless an applicable federal statute, regulation, or DCM rule prescribes a different timeline, in which case the operator shall comply with the federally prescribed timeline," and require notice "within 24 hours or within the shorter federally required notification period if one applies." - The State Gaming Regulator: Rationale: This suggestion closes gaps in PMCPS-M §503(b-1), which permits settlement correction when a resolution source revises its determination but does not specify a time limit or the participant's right to contest. Without a deadline, the operator can delay notification indefinitely and suppress participant knowledge. Without an explicit contest right tied to the revision, §503(b-1) permits unilateral settlement rewrite. The fourteen-day window aligns with §504(a)'s contest period and prevents tail risk. - The Participant Advocate: Imposing a 14‑day correction window, 24‑hour notice of source revisions, and an explicit contest right prevents indefinite unilateral settlement revisions and ensures timely participant notice and ability to dispute. - The Minimal Intervention Advocate: Rationale: This suggestion adds a 14-day deadline for correcting settlements under §503(b-1) and requires 24-hour notification to participants with an explicit contest right. The Polymarket MicroStrategy case illustrates the harm: indefinite tail risk for participants when an operator delays notifying them of a resolution-source revision. The 14-day window aligns with the existing contest period in §504(a) and prevents the operator from silently rewriting settlement.

S015 key rationales: - The Derivatives Regulator: Requiring an adopting authority's written equivalence determination, the operator's documentation of its equivalence claim, and filing of that determination with the assessor removes the operator's unilateral self‑exemption and gives assessors objective documentary basis to verify scope. - The State Gaming Regulator: Rationale:** This suggestion eliminates self-administered waiver authority in PMCPS-C §104(g)(1). Currently, an operator can unilaterally determine whether its licensing regime is "equivalent" to PMCPS-M Parts 300-500, converting a scope exclusion into a self-judged waiver. The operator has a direct financial incentive to find equivalence, and an assessor has no binding standard to verify the claim. The amendment requires the adopting authority to make a written equivalence determination and file it before the product is offered. - The Exchange Operator: Prevents operator self‑waiver and restores assessability with minimal cost: require the adopting authority’s written equivalence determination be obtained and filed before offering and retained in the operator’s assessor package. - The Participant Advocate: Replaces operator self‑certification with a required adopting‑authority written equivalence determination and filed evidence so operators cannot unilaterally exempt products from PMCPS‑M protections that matter to participants. - The Settlement and Integrity Specialist: PMCPS-C § 104(g)(1) permits an operator to self-judge whether its licensing regime is "at least equivalent" to PMCPS-M Parts 300-500. This converts a scope exclusion into a self-administered waiver: the operator has a direct financial incentive to find equivalence, and an assessor has no binding standard for verification.

4b. Package Ratification

Ballot:

S001: Replace PMCPS‑C §102(a) with the following text, and insert the following sentence at the end of PMCPS‑C §105(b) (to be read as part of §105(b)). New PMCPS‑C §102(a) (replacement) "This standard determines scope. Except for the procedural recordkeeping, filing, and classification‑documentation obligations set out in §105 and the reclassification obligations in §106, it imposes no operational design, system, or trading conduct requirements on a covered operator. The obligations in §105 and §106 are classification and records obligations and are enforceable as stated." Insertion to PMCPS‑C §105(b) (new evidence requirement) "The written determination shall be accompanied by, and the covered operator shall retain and produce on request, an evidence package sufficient for an assessor or any applicable regulatory authority to verify the classification. The evidence package must include: (i) an evidence map that links each discrete conclusion reached under Gates 1-4 to one or more contemporaneous source records or, where contemporaneous raw source records cannot be produced, to contemporaneous metadata, attestation, or validated system audit log excerpts; each link must identify the class of source evidence, a unique identifier for the record or extract relied on, and a timestamp for when the source evidence was created or captured; (ii) a copy of the product specification and full settlement terms relied on for the determination, or, where a substantially equivalent document exists within the operator's routine system of record (for example, a trade capture record, rulebook entry, or operational configuration file), a reference to that record together with the location and identifier in the evidence map; (iii) where the operator relies on a PMCPS‑M deliverable (for example, a machine‑readable resolution specification described in PMCPS‑M §501(a)(7) or proof of signatory designation under PMCPS‑M §204(a)), the operator shall either (A) produce the PMCPS‑M deliverable and any cryptographic hash it maintains, or (B) explain in the evidence map why the referenced PMCPS‑M provision is not applicable to this product and furnish the equivalent system record or attestation relied upon in its stead; (iv) examples of the participant‑facing disclosures or descriptions used at or about order entry, identified in the evidence map by version identifier and timestamp; where an operator cannot produce original participant display artifacts for confidentiality or system‑architecture reasons, the operator may provide a contemporaneous version identifier, a sanitized or redacted rendering, or a signed attestation describing the disclosure as presented and the method used to display it, together with the location and identifier used in the evidence map; (v) where the classification relies on participant position, hedging, or account relationship information, the evidence map must identify the category of account or ledger evidence relied on and provide, as appropriate, sanitized extracts, system identifiers, transaction identifiers, or attestations sufficient to permit verification without disclosing unnecessary confidential counterparty data; and (vi) documentary evidence of the identity and authority of the signatory required by §105(c) and evidence of that individual's designation in the operator's internal designation records (which may, where applicable, be the record required by PMCPS‑M §204(a)). For purposes of this paragraph, 'contemporaneous' means created at or within a reasonable timeframe of the event the Gate analysis relies upon (for example: documentation created at product launch for Gate 1; execution records for Gate 3 conclusions; system configuration records contemporaneous with the period of tradability evaluated). The evidence map must state the rationale for any date range relied on and identify the applicable retention period for each class of evidence. All materials in the evidence package must be retained for the period stated in §105(f). Where the covered operator is a designated contract market, clearing organization, or otherwise subject to federal recordkeeping obligations, the operator may satisfy the requirements of this paragraph by producing the records it is required to retain under applicable federal law (including, as applicable, 17 C.F.R. Parts 1, 38 and 40) together with an evidence map that links those federal records to the Gate conclusions. Where raw source records are unavailable to the assessor because they contain confidential participant data or are otherwise protected, the operator may supply redacted extracts, metadata, validated audit log excerpts, or attestations sufficient to permit verification; the operator must document in the evidence map the legal or operational basis for any redaction or limitation and provide a reasonable method by which an appropriate regulatory authority may obtain full records under that authority's legal powers." [obligations: +3 PMCPS-C] S002: "Alternative pathway for a registered designated contract market. Where the covered operator is a registered designated contract market (DCM) under the Commodity Exchange Act, the DCM may satisfy paragraphs (a)-(c) by producing, in lieu of a separate independent laboratory certification, the contemporaneous filings, attestations, testing artifacts, and independent reports the DCM is required to generate or files voluntarily under the Commodity Exchange Act and 17 C.F.R. Parts 38 and 40, subject to the following requirements: (1) The DCM shall produce date‑stamped copies of all filings and attestations submitted to the Commission that relate to system safeguards, system testing, product self‑certification, or other testing of systems that map to PMCPS‑M §207 (including but not limited to attestations and testing performed under 17 C.F.R. §§38.1050-38.1051 and any Part 40 self‑certification submissions). Where information contained in those materials is reasonably expected to reveal trade secrets, proprietary source code, or other confidential implementation details, the DCM may instead produce a redacted copy together with a contemporaneous unredacted‑access arrangement as described in paragraph (1)(b) below. The DCM shall accompany any redacted submission with a redaction log that (i) identifies each redacted item, (ii) states the basis for the redaction (for example: trade secret, third‑party confidential information), and (iii) cites the specific PMCPS‑M §207 element(s) for which the redacted item is claimed non‑material. (a) Unredacted‑access arrangement. In lieu of producing unredacted materials in public form, the DCM may provide secure, confidential access to unredacted materials to an assessor or an applicable regulatory authority under terms that preserve commercially sensitive information. Secure access may include (without limitation) on‑site review under controlled conditions, secure remote access to a read‑only environment, or review under a confidentiality protocol acceptable to the assessor or applicable regulatory authority. The DCM shall retain contemporaneous records evidencing the secure‑access arrangement (access logs, timestamps, and the identity of persons granted access). (2) The DCM shall produce any independent laboratory reports relied upon in those filings, and the laboratory credentials and scope of accreditation for those reports. If no independent laboratory report exists for an element that is covered by a filing or attestation, the DCM shall produce a contemporaneous explanation identifying the testing that was performed, the party that performed it, and why an independent laboratory report was not produced. (3) The DCM shall produce an explicit mapping (a matrix) that ties each CFTC filing, testing artifact, attestation, and independent report to the specific PMCPS‑M §207 obligation(s) it covers. The mapping shall identify, for each linked artifact, the test identifier(s), test date(s), and the scope or objective of the test. Where a system build version is material and available without disclosing proprietary implementation detail the mapping shall include the system build version and the date of the build; where a build‑version disclosure would reveal proprietary implementation details the DCM may instead provide vendor test identifiers, test‑version markers, or other vendor‑supplied markers used in the testing lifecycle as equivalent metadata. Where public filings omit implementation metadata, the DCM may supply a contemporaneous attestation describing the equivalence of the metadata it can provide to the metadata ordinarily requested by an assessor. (4) Where any PMCPS‑M §207 element is not demonstrably covered in the Part 38/40 filings and artifacts, the DCM shall produce the additional test artifacts, remediation records, retest evidence, or attestations necessary to demonstrate compliance with that PMCPS‑M §207 element. If full public disclosure of additional artifacts would disclose proprietary material, the DCM may satisfy this requirement by producing redacted artifacts together with secure unredacted access under paragraph (1)(a) and by supplying a redaction log. (5) Where the Commission or its staff has issued a directive, stay, or advisory that affects the DCM's testing, monitoring, or listing practices (for example CFTC Staff Advisories regarding continuous monitoring, system safeguards, or product self‑certification), the DCM shall produce the directive or advisory and demonstrable evidence of contemporaneous compliance with it. (6) The DCM shall retain all materials produced under this paragraph-including redaction logs and secure‑access records-for five years and shall produce them to an assessor or any applicable regulatory authority on request. Nothing in this paragraph relieves the DCM of any filing, recordkeeping, or production obligation the DCM otherwise has under the Commodity Exchange Act or 17 C.F.R. Parts 38 and 40, nor does it limit any statutory or regulatory authority of the Commission or an applicable regulatory authority to require unredacted materials when authorized to do so." [obligations: none] S004: Amend PMCPS-M § 602(a) to add a new reporting item (10): "the number of participants whose accounts were flagged by RG triggers under § 304(a)(10) but for whom the operator declined to designate 'at-risk' status, reported in the aggregate and de-identified consistent with applicable privacy law, aggregated by the operator's published declination-explanation taxonomy and presented in minimum-cell-suppressed bands where any cell contains fewer than five participants." Amend PMCPS-M § 601(a)(9) to specify that the operator shall retain "the RG trigger event logs, the at-risk designation records, and the five-year retained explanations for each declination to designate at-risk status, maintained in a de-identified format accessible only to the operator's compliance personnel and to authorized examiners." Add a new obligation to PMCPS-M § 301: "The operator shall publish, in its RG program documentation filed under § 601(a)(9), the complete declination-explanation taxonomy it uses to categorize reasons for declining at-risk designation. The taxonomy shall be established before the operator begins reporting under § 602(a)(10), shall remain stable for each calendar year, and shall be updated prospectively only." [obligations: +2 PMCPS-M] S005: Amend PMCPS-M § 501(a)(7) to require that the facts presented to the participant on the order-entry screen include: "(8) whether the resolution source has a documented track record of timely, unambiguous publication of determinations for at least twelve months prior to listing, and if not, the reasons the covered operator believes the source will perform reliably; and (9) the covered operator's policy for settlement correction under § 503(b) and (b-1), including the period within which a correction may be made and the procedure by which a participant may contest a settlement under § 504." Amend PMCPS-M § 505(a) to add a new item (7): "the covered operator has reviewed the resolution source's publication history, where available, and has documented its assessment that the source is capable of publishing determinations in accordance with the resolution specification." [obligations: +2 PMCPS-M] S006: Remove PMCPS-M § 301(d)(1) and § 301(d)(2) entirely. Replace § 301(d) with: "(d) Excluded Participant Position Management. An excluded participant retains the right to receive amounts owed under § 301(c). A covered operator shall, at the moment an exclusion is enacted: (1) permit the excluded participant to place risk-reducing orders and position-closing orders without penalty or additional margin requirement; (2) provide the excluded participant, in both human-readable form and as a machine-readable file linked from the UI and recorded in the UI snapshot, a clear statement of the exit options available under this subsection; and (3) if the operator elects to offer a one-time optional liquidation at a firm reference price, disclose in plain language: the liquidation procedure; the reference price method; the settlement timeline; and any fees or adjustments that will apply. The operator shall record this disclosure and the participant's acceptance or rejection in the UI snapshot." [obligations: -1 PMCPS-M] S008: Replace the previously-proposed insertion to PMCPS‑M with the following, to be added as new paragraphs and items at the cited locations. 1) Add new paragraph §502(e) (and renumber following subparagraphs if necessary): "(e) Documentary proof of resolution‑source independence and contemporaneous capture. For every resolution source identified in a contract's resolution specification under §501, a covered operator shall retain and produce on request the following evidentiary artefacts: (1) Independence documentation. Either (A) a written conflict‑of‑interest and independence statement for the resolution source, signed by an authorised representative of the source, or (B) where such a signed statement cannot reasonably be obtained, a completed and signed operator‑maintained conflict checklist describing known affiliations, commercial relationships, or other matters relevant to assessing the source's independence from the operator and its affiliates at the time the source was designated for use. (2) Contemporaneous capture of the item consulted at settlement. For each settlement action that uses a resolution source, the operator shall retain a contemporaneous archival capture of the exact item consulted at settlement together with retrieval metadata sufficient for an assessor to reconstruct the retrieval and verify integrity. For machine‑accessible resolution sources the capture and metadata shall include, at minimum: the full response body returned by the source; relevant transport and protocol metadata (for example HTTP headers where applicable); the exact request issued to the source; the retrieval timestamp expressed in coordinated universal time (UTC) with timezone indicator; and a cryptographic hash of the response body. For human or other non‑machine sources the capture and metadata shall include, at minimum: a contemporaneous signed transcript, audio recording, or other documentary record of the item consulted; the retrieval timestamp in UTC; and the operator's contemporaneous description of the method and identity of the person(s) who retrieved it. (3) Linkage metadata. Each archival capture required by (2) must be explicitly tied to the settled contract and to the specific settlement action that used it by recording the contract identifier, settlement timestamp, and internal settlement transaction identifier or equivalent. (4) Remediation where independence is lacking. Where the documentation produced under (1) shows that the resolution source is (or was at designation time) entity‑affiliated with the operator or otherwise fails to satisfy the applicable independence expectations, the contract's resolution specification must identify and bind a pre‑identified independent adjudicator or alternative independent source as permitted by §501(a)(4)." 2) Add new paragraph §502(f) (transitional compliance): "(f) Transition for live platforms. For covered operators that, on the effective date of this provision, have operational settlement workflows that did not previously produce all items required by §502(e), full compliance is required no later than twelve (12) months after that effective date. During the transition period the operator must preserve and produce any contemporaneous captures and metadata that were generated under existing practices, and shall provide a written interim statement of the steps being taken to achieve full compliance. For settled contracts whose settlement action occurred before the effective date of this provision, the operator shall, on assessor request, produce best‑effort reconstructions and any available contemporaneous records for the two (2) years preceding the effective date; where no contemporaneous record exists, the operator shall so attest." 3) Add advisory sentence at §502(c) (or insert as a short advisory paragraph immediately following §502): "The archival captures and independence documentation required by §502(e) are the evidentiary artefacts an assessor will request to verify compliance with the independence and settlement‑integrity obligations in Part 500." 4) Amend PMCPS‑M §601(a) retention list by inserting a new item (12) after current (11): "(12) the archival captures, retrieval metadata, independence documentation, linkage metadata, and any related chain‑of‑custody records required by §502(e), retained in tamper‑evident archival form with cryptographic hashes, time‑stamps, and chain‑of‑custody logging sufficient to permit forensic reconstruction and integrity verification by an assessor, for not less than five (5) years from the date of settlement." Notes on implementation scope within the normative text: - The provisions above specify required evidentiary content and minimal integrity controls (cryptographic hashes, UTC timestamps, chain‑of‑custody logging) but do not mandate a particular storage technology or vendor solution. Operators may satisfy the tamper‑evident and chain‑of‑custody requirements by any credible technical means (for example, append‑only/WORM storage with signed manifests and timestamped audit logs, notarisation, or equivalent measures) so long as the retained artefacts permit an assessor to verify provenance and integrity and to reconstruct the retrieval used at settlement. - These provisions are post‑settlement evidentiary and retention requirements. They require capture at or immediately after settlement and retention thereafter; they do not impose any verifiable obligation that can be enforced at the point of order entry because the content to be captured does not yet exist at entry time." [obligations: none] S010: Replace PMCPS-M § 501(a)(7) with the following paragraph, and add a new subparagraph to PMCPS-M § 601 as specified: PMCPS-M § 501(a)(7) (replacement) Before the participant submits an order, and again in the order-confirmation message, the covered operator shall present the following facts to that participant in both human‑readable form and as a machine‑readable file accessible from the UI: (A) the resolution source by name and by a unique machine identifier (for example, a URL or a content‑addressed identifier); (B) a single‑sentence plain‑language settlement condition derived from § 501(a)(1); (C) the exact Coordinated Universal Time at which the resolution source will be consulted under § 501(a)(3); (D) whether the resolution source is independent of the covered operator or is the covered operator, an affiliate, or a person compensated by the covered operator; and (E) whether that resolution source or the contract type is currently subject to a known regulatory review, prohibition, or stay. For each order submitted the covered operator shall, and shall retain for not less than five years, the evidence described in either route (1) or (2) below; the operator may choose the route per order or per disclosure where appropriate, but must preserve the chosen evidence form in a manner that is auditable and accessible to the participant as required in paragraph (3): (1) Per‑order immutable UI snapshot option. Create an immutable, time‑stamped, content‑addressed record (a “UI snapshot”) that captures the exact human‑readable text and the machine‑readable file presented to that specific participant on the order‑entry screen and the exact order‑confirmation message delivered to that participant; the UI snapshot must include the participant account identifier, order identifier, the system timestamp, and the machine identifier of the machine‑readable resolution specification. OR (2) Contract‑version artifact plus per‑order reference option. Where the disclosure presented to the participant is identical to a previously created disclosure artifact for the same contract‑version, create and retain a time‑stamped, content‑addressed disclosure artifact (the human readable text together with the machine‑readable file) and for each order generate an immutable per‑order record that includes the participant account identifier, order identifier, the system timestamp, and the machine identifier of the disclosure artifact that was shown to the participant. The per‑order record must be sufficient to demonstrate which disclosure artifact was presented to that participant at the time the order was placed. (3) Participant access to the evidence. For every order the covered operator shall make available to the participant, from the participant’s account order history without contacting customer service, the disclosure evidence that proves what the participant was shown under (1) or (2). The order confirmation message must include the disclosure’s machine identifier and clear instructions for obtaining the associated evidence from the participant’s account order history; the operator may implement the required account‑history access by any secure technical means so long as the participant can retrieve the exact disclosure evidence for their order directly from their account history. This paragraph does not remove or replace any existing record retention obligations elsewhere in this standard; it adds explicit, auditable evidence forms that prove compliance with the pre‑trade and order‑confirmation disclosure obligations and a participant right to download the disclosure evidence from their account history. PMCPS-M § 601 (addition - add as § 601(a)(12)) (12) The disclosure artifacts, UI snapshots, and per‑order records created under § 501(a)(7), each retained for not less than five years and made accessible to the participant from the participant’s account order history as required by § 501(a)(7). This requirement supplements and does not limit any other record retention obligations in these standards. [obligations: +4 PMCPS-M] S013: Amend PMCPS-M § 501(a)(6) to require that the period within which a correction under § 503(b) or § 503(b-1) may be made shall not exceed fourteen calendar days from the date of settlement publication, and amend § 503(b-1) to require that a covered operator shall notify affected participants of any resolution source revision within twenty-four hours of learning of it, together with a plain-language explanation of the revision and its effect on settlement, and shall permit participants to contest the revised settlement under § 504 notwithstanding that the original settlement was already published. [obligations: +2 PMCPS-M] S015: Amend PMCPS-C § 104(g)(1) to read: "offered under a licence issued by a gaming regulatory authority that imposes requirements at least equivalent to Parts 300 through 500 of these Standards and supervises compliance with them, provided that (i) the operator documents the basis for claiming equivalence, (ii) the adopting regulatory authority has made a written determination that the licensing regime meets the equivalence standard, and (iii) that determination is filed with the operator's assessor before the product is first offered." Replace the current language in PMCPS-C § 105(b)(5) with: "where an exclusion under § 104(g)(1) is relied on, the licence relied on, the adopting authority's written equivalence determination, and the date of that determination." Add to PMCPS-C § 106(a) a new trigger: "(5) withdrawal or material modification of an equivalence determination made under § 104(g)(1)." [obligations: +2 PMCPS-C]

PMCPS-C: 19 -> 24 (+5)
PMCPS-M: 186 -> 195 (+9)
Family: 205 -> 219 (+14)

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.

Result: RATIFIED: 5 yes / 1 no / 0 abstain (83%, threshold 51%)

6. Provenance

Regeneration: not eligible. 47 of 47 calls were not pinned. Retained artifacts allow the session to be replayed, but not regenerated: - claude:claude-haiku-4-5: claude does not honour temperature 0 with a fixed seed - claude:claude-sonnet-5: claude does not honour temperature 0 with a fixed seed - openai:gpt-5-mini: openai does not honour temperature 0 with a fixed seed

Calls: 47. Tokens in/out: 494768 / 103824. 47 call(s) have no cost: no price is declared for their model.

Prompt sha256 shows the FIRST SIXTEEN characters only; a recomputed digest is sixty-four characters and will not equal it.

Hash Chain

Each section is hashed, and each hash is chained to the one before it. Editing any section changes every hash below it, including the head.

The two hash columns show only the FIRST SIXTEEN characters of each sha256, for width. A recomputed sha256 is sixty-four characters and will not equal the sixteen printed here. Compare prefixes, or use the verifier, which compares in full. The head hash below this table is complete.

Head hash: ab885f868054dc6340cc2b3fe5d4668fc9622df4fccc3ccaed6718a1816d637e

The chain covers every section of these minutes except this one, which cannot contain its own hash. Recompute with python3 -m runner.verify_chain <minutes file>.

5. Completion

Timestamp: 2026-10-02T11:25:28+00:00 Configured actions: report, publish

• report OK: report present and current at /mnt/d/tools/apps/predmarket-standards/logs/report-2026-10-02.md
• publish OK: pass list published to /mnt/d/tools/apps/predmarket-standards/logs/published/latest.json (and pmcps-committee-2026-10-02.json)

6b. Sections Rewritten During This Session

A phase re-run rewrites its section. Each entry records what it replaced. Hashes show the first sixteen characters only.

• 2026-10-02T10:55:56+00:00 ## 5. Completion: e4a2066ad952de50 replaced a28a159523e28883
• 2026-10-02T10:55:57+00:00 ## Hash Chain: d55999b88d197ec5 replaced 29d4653f37b84600
• 2026-10-02T11:25:28+00:00 ## 5. Completion: e513c12fce1e6b9a replaced e4a2066ad952de50
• 2026-10-02T11:25:28+00:00 ## 6. Provenance: 59ad5c51f11547eb replaced 8a768c449738f832