- Railbird Exchange, doing business as DKeX, self-certified nine football event contracts with the CFTC on Monday.
- The contract terms reach NFL, CFL and UFL play and NCAA Division I, II and III football alike.
- The submissions become certified by Wednesday under a rule that requires no commission decision.
- A separate COMBOS contract, certified by Aug. 11, settles on the joint outcome of two or more listed contracts.
WASHINGTON – Railbird Exchange LLC, the DraftKings-owned exchange doing business as DKeX, self-certified nine football event contracts with the Commodity Futures Trading Commission on Monday. The submissions become certified by Wednesday and can be listed for trading thereafter.
The Nine Contracts The Filings Name
The nine product certifications filed on Monday are FOOTBALLWIN, FOOTBALLSPREAD, FOOTBALLTOTALS, FOOTBALLENTITYSTAT, FOOTBALLGAMESTAT, FOOTBALLENTITYACHIEVEMENT, FOOTBALLENTITYOUTPERFORM, FOOTBALLAWARD and FOOTBALLOUTRIGHT. The CFTC lists all nine as swaps in the event category, filed under the registered entity code REX.
Each contract states its underlying as a question. FOOTBALLWIN asks, “Will [entity] win [time period] of [event]?” FOOTBALLSPREAD asks, “Will [entity] record a point differential relative to [opponent] of [condition] [count] during [time period] of [event]?” FOOTBALLTOTALS asks, “Will [entity] score [condition] [count] total points during [time period] of [event]?” FOOTBALLGAMESTAT asks, “Will [event] produce [condition] [count] [statistic] during [time period]?”
Player statistics and team statistics sit in one contract rather than two. FOOTBALLENTITYSTAT settles on whether “a designated football player or team records a statistical output satisfying a specified condition and threshold during a specified time period.” FOOTBALLENTITYACHIEVEMENT is written the same way for in-game achievements, reaching a player or a team under a single set of terms.
FOOTBALLENTITYOUTPERFORM matches one player against one or more designated opponents on a specified metric. FOOTBALLAWARD applies to season-long awards confirmed by the awarding body, and FOOTBALLOUTRIGHT settles on competition placement.
Railbird has been a CFTC-designated contract market since June 2025. DraftKings announced the acquisition on Oct. 21, 2025, about three months after word that DraftKings eyes Railbird first emerged.
NCAA Football Sits Inside The Contract Terms
The scope written into the terms goes past the professional game. FOOTBALLENTITYSTAT states that the subject “may refer to individual players or teams in any professional or collegiate football competition recognized by the Exchange, including the NFL, CFL, UFL, and NCAA competition, or any other organized football competition at the collegiate level or higher.” FOOTBALLWIN names “collegiate teams (NCAA Division I, II, or III).” FOOTBALLENTITYOUTPERFORM applies the same language to individual college players matched against each other.
The exchange also wrote a separate data path for the college game. Its source hierarchy runs from the governing body of the event to major media organizations, naming ESPN, The Associated Press and NFL.com, then official broadcasters. To determine whether a player participated, the exchange may additionally rely on snap count data from a vetted data provider for the NFL and “internally scouted player status data” for the NCAA.
The exchange settles on the first authoritative result a source agency reports unless it decides, in its “sole and absolute discretion,” that the result is clearly erroneous. Corrections issued after expiration do not change settlement.
What Self-Certification Requires
DKeX filed under CFTC Regulation 40.2, a filing-and-wait process rather than an approval process. Each letter to the commission’s Office of the Secretariat states that the exchange “is certifying to the Commodity Futures Trading Commission, pursuant to CFTC Regulation 40.2, the initial listing” of the contracts.
Each letter also includes a concise explanation and analysis of the product, the intended listing date, the contract terms as an appendix, and a list of prohibited contract participants. Under Section 5c of the Commodity Exchange Act and 17 C.F.R. 40.2, the exchange certifies that the contracts comply with the act and the commission’s regulations, and that it has posted a notice of pending certification and a copy of the submission on its own website.
Miles Saffran, the exchange’s chief executive officer and president, signed each letter. Eight of the nine state that the submission “shall become certified by August 12, 2026, and the Contracts will be listed for trading on the Exchange thereafter.” The FOOTBALLENTITYOUTPERFORM letter runs the same sentence with the date left unfilled, as “August XX, 2026.” No commission decision appears anywhere in the documents.
That is the structural difference between these products and the state-licensed market behind legal sports betting in the United States, where a new product type generally waits on a regulator.
How COMBOS Settles
DKeX filed the combination product Aug. 7 as submission 62448, three days before the football set, and its letter set certification by Aug. 11. Its underlying is “Will all [outcomes] occur?” The COMBOS certification states that the contract “settles on the joint outcome of two or more constituent contracts, each of which is separately listed on the Exchange and separately certified pursuant to Commission Rule 40.2.”
The exchange is explicit that it is not building anything new underneath. “The COMBOS does not introduce a new underlying, settlement methodology, or data source,” the filing says. Each component resolves under its own contract specifications, and the COMBOS “governs only the aggregation of those independently determined results.” Its settlement value for YES is the product of the component settlement values.
The filing sets limits on how a COMBOS can be built. It needs a minimum of two components, each referencing a different constituent contract, and the same constituent cannot appear twice on either side. A component may not itself be a COMBOS. If any component resolves to $0.00, YES settles at $0.00 regardless of how the rest resolve, and the contract may settle on an accelerated basis under Rule 7.2 of the exchange rulebook.
The Terms Every Contract Shares
All ten filings carry identical trading terms. Each contract is sized at $1.00 of notional value with a minimum price fluctuation of one cent, may be listed only at values between $0.01 and $0.99, and carries a position accountability level of 125,000 contracts. Trading runs 24 hours a day and seven days a week outside announced maintenance windows.
Because a binary contract resolves to $1.00 or $0.00, the price at which one trades implies a probability rather than reporting one, the same relationship a payout price carries on prediction market apps generally.
The football filings note that additional competitions may be added by amendment under Part 40 of the commission’s regulations, and the COMBOS filing says contract types eligible for inclusion as components may be added as further contracts are certified. Neither route requires a new commission decision.
