# CFTC Letter No. 26-12: Gemini Titan LLC (“Titan”) and Gemini Olympus, LLC (“Olympus”) request a no-action position, on their own behalf and on behalf of their participants, from the swap data reporting and recordkeeping requirements of regu..

> Federal · Agency guidance · In force

URL: https://www.frixlaw.com/law-library/statutes/CFTC_L26_12

## Section

- **Citation:** CFTC Letter No. 26-12
- **Heading:** Gemini Titan LLC (“Titan”) and Gemini Olympus, LLC (“Olympus”) request a no-action position, on their own behalf and on behalf of their participants, from the swap data reporting and recordkeeping requirements of regu..
- **Jurisdiction:** Federal
- **Kind:** Agency guidance
- **Status:** In force
- **Text as of:** August 14, 2026
- **Source:** Compiled text
- **Location:** CFTC Staff Letters (2008-present) / Gemini Titan LLC (“Titan”) and Gemini Olympus, LLC (“Olympus”) request a no-action position, on their own behalf and on behalf of their participants, from the swap data reporting and recordkeeping requirements of regu...

## Text

Summary: Gemini Titan LLC (“Titan”) and Gemini Olympus, LLC (“Olympus”) request a no-action position, on their own behalf and on behalf of their participants, from the swap data reporting and recordkeeping requirements of regulations 38.8(b), 38.10, 38.951 (to the extent that regulation 38.951 requires compliance with Part 45 of the Commission’s regulations), 39.20(b)(2), along with Parts 43 and 45 of the Commission’s regulations. Titan and Olympus request a no-action position with respect to reporting contracts with a binary payout structure and contracts with a variable payout structure with the features described in the letter, traded and cleared pursuant to Titan and Olympus’s rules.

CFTC LETTER NO. 26-12 NO-ACTION MAY 01, 2026
1

Division of Market Oversight
Division of Clearing and Risk

Re:
Supplemental No-Action Position with Respect to Commission Regulations 38.8(b),
38.10, 38.951 (in Part), 39.20(b)(2), and Parts 43 and 45, for Certain Contracts
Traded on or Pursuant to the Rules of Gemini Titan LLC and Cleared by Gemini
Olympus, LLC

Introduction

The Division of Market Oversight (“DMO”) and the Division of Clearing and Risk (“DCR”
and, together with DMO, the “Divisions”) of the Commodity Futures Trading Commission
(“CFTC” or “Commission”) are issuing this letter in response to a request1 (the “Request”) from
Gemini Titan LLC (“Titan”) and Gemini Olympus, LLC (“Olympus”). Titan and Olympus request
a no-action position, on their own behalf and on behalf of their participants, from the swap data
reporting and recordkeeping requirements of regulations 38.8(b), 38.10, 38.951 (to the extent that
regulation 38.951 requires compliance with Part 45 of the Commission’s regulations), 39.20(b)(2),
along with Parts 43 and 45 of the Commission’s regulations (collectively, the “Relevant
Regulations”)
a no-action position, on their own behalf and on behalf of their participants, from the swap data
reporting and recordkeeping requirements of regulations 38.8(b), 38.10, 38.951 (to the extent that
regulation 38.951 requires compliance with Part 45 of the Commission’s regulations), 39.20(b)(2),
along with Parts 43 and 45 of the Commission’s regulations (collectively, the “Relevant
Regulations”). Titan and Olympus request a no-action position with respect to reporting contracts
with a binary payout structure and contracts with a variable payout structure with the features
described in this letter, traded and cleared pursuant to Titan and Olympus’s rules. Titan is a
designated contract market (“DCM”) and Olympus is a registered derivatives clearing organization
(“DCO”).

The Divisions have previously granted a similar request applicable to contracts traded on
Titan and cleared through QC Clearing LLC d/b/a Polymarket Clearing (“QC”).2 For the same
reasons the Divisions granted that previous request, the Divisions have decided to grant a
supplemental no-action position3 addressing contracts with the features described in this letter that
are cleared through Olympus.

1 Letter from N. Ignoffo to R. Varma and R. Haynes re: Gemini Olympus, LLC - Regarding No-Action Position for
Commission Regulations 38.8(b), 38.10, 38.951 (In Part), and 39.20(b)(2), and Parts 43 and 45, for Contracts Cleared
by Gemini Olympus, LLC and Traded On or Pursuant to the Rules of Gemini Titan, LLC (Dec. 12, 2025) (the
“Request”).
2 CFTC Letter No. 25-44 (Dec. 11, 2025), available at https://www.cftc.gov/csl/25-44/download.
3 The Request seeks a no-action position “to extend the previously granted relief to Olympus on an equal basis with
QC.” Request at 1 n.1.
U.S. COMMODITY FUTURES TRADING COMMISSION
Three Lafayette Centre, 1155 21st Street, NW, Washington, DC 20581
www.cftc.gov
Dec. 12, 2025) (the
“Request”).
2 CFTC Letter No. 25-44 (Dec. 11, 2025), available at https://www.cftc.gov/csl/25-44/download.
3 The Request seeks a no-action position “to extend the previously granted relief to Olympus on an equal basis with
QC.” Request at 1 n.1.
U.S. COMMODITY FUTURES TRADING COMMISSION
Three Lafayette Centre, 1155 21st Street, NW, Washington, DC 20581
www.cftc.gov

2

Background

The Request states that Titan lists “contracts on the outcomes of various events” (the “Titan
Contracts”).4 The Titan Contracts “have a settlement structure that (i) can result in a payout to
both counterparties to the contract (although by definition, only one side of the contract can profit,
meaning receive a payout in excess of basis) and (ii) whose settlement obligations vary based on
the amplitude by which the price at expiration exceeds the strike or strike price.”5 The Request
states that Titan Contracts “are fully collateralized” and require “each participant to post at
execution sufficient funds to cover the position's maximum potential loss. Consequently, Titan
does not create uncollateralized credit exposure typical of traditional swaps.”6 The Request further
states that the Titan Contracts have “preset price caps and floors that limit potential profit and
loss.”7 In addition, the Request indicates that Titan “intends to permit participants to clear Titan
Contracts through third-party clearing members who are registered clearing members of QC or
Olympus.”8

The Request represents that Titan Contracts are swaps under the Commodity Exchange
Act (“CEA”) as they “provide for a payment that is dependent on the occurrence, nonoccurrence,
or the extent of the occurrence of an event or contingency associated with a potential financial,
economic, or commercial consequence.”9 However, as stated in the Request, “the Titan Contracts
share most of the characteristics of exchange traded futures or options thereon (fungibility, offset,
exchange traded with standardized terms
payment that is dependent on the occurrence, nonoccurrence,
or the extent of the occurrence of an event or contingency associated with a potential financial,
economic, or commercial consequence.”9 However, as stated in the Request, “the Titan Contracts
share most of the characteristics of exchange traded futures or options thereon (fungibility, offset,
exchange traded with standardized terms on a single marketplace) with few of the indicia of
traditional swaps (bilateral, traded over-the-counter, and customized).”10 The Request further
stated that “potential market participant exposures associated with the Titan Contracts are
anticipated to be far lower than those associated with traditional swaps and with swaps market
participants.”11 As such, the requesters believe that “the regulatory goals of Part 43 and Part 45
have limited to negligible application to Titan Contracts.”12

CEA section 4c(b), in relevant part, prohibits any person from offering, entering into, or
confirming the execution of a transaction involving any commodity regulated under the CEA that
“is of the character of, or is commonly known to the trade as, an ‘option’ . . .” contrary to any
Commission rule prohibiting the transaction or allowing it pursuant to specified terms and
conditions.13 When promulgating Commission Regulation 32.2, the Commission stated that “the
swap definition . . . includes options . . . (whether or not traded on a DCM)[.]”14 Commission
Regulation 32.2 states, in relevant part, that commodity option transactions must be conducted in
compliance with the CEA and the Commission’s regulations related to swaps.15

4 Request at 1.
5 Request at 2.
6 Request at 1.
7 Request at 2.
8 Id.
9 Id.
10 Request at 4.
11 Id.
12 Id.
13 7 U.S.C. § 6c(b).
14 Commodity Options, 77 Fed. Reg. 25320, 25321, n.6 (Apr. 27, 2012).
15 17 C.F.R. § 32.2.
n 32.2 states, in relevant part, that commodity option transactions must be conducted in
compliance with the CEA and the Commission’s regulations related to swaps.15

4 Request at 1.
5 Request at 2.
6 Request at 1.
7 Request at 2.
8 Id.
9 Id.
10 Request at 4.
11 Id.
12 Id.
13 7 U.S.C. § 6c(b).
14 Commodity Options, 77 Fed. Reg. 25320, 25321, n.6 (Apr. 27, 2012).
15 17 C.F.R. § 32.2.

3

The Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”)16
amended the CEA by adding a definition of “swap.”17 The Dodd-Frank Act required the
Commission and the Securities and Exchange Commission to further define jointly the term
“swap,” and in 2012, the Commissions jointly adopted such further definition.18

Pursuant to the Dodd-Frank Act, the Commission promulgated various regulations
applicable to swaps, including the Relevant Regulations. The Relevant Regulations apply swap
reporting and recordkeeping obligations to DCMs, DCOs, and other market participants. In
particular, Parts 43 and 45 require, respectively, real-time reporting of swap transaction and pricing
data to swap data repositories (“SDRs”) for purposes of public dissemination and reporting of
broader swap data to SDRs for the Commission’s use in fulfilling its surveillance and market
analysis missions.

No-Action Position Requested

Titan and Olympus request that the Divisions not recommend the Commission take
enforcement action against Titan or Olympus or their participants for failure to report Titan
Contracts to an SDR or to fulfill any of the other requirements of the Relevant Regulations. In
requesting that no-action position, Titan and Olympus seek to extend the no-action position taken
with respect to Titan and QC in CFTC Letter No. 25-44.19 Titan and Olympus state that the
requested no-action position is comparable to the no-action positions concerning reporting of
similar contracts provided in Commission Letters Nos
y of the other requirements of the Relevant Regulations. In
requesting that no-action position, Titan and Olympus seek to extend the no-action position taken
with respect to Titan and QC in CFTC Letter No. 25-44.19 Titan and Olympus state that the
requested no-action position is comparable to the no-action positions concerning reporting of
similar contracts provided in Commission Letters Nos. 17-31, 17-32, 21-11, 24-09, 24-12, 25-02,
25-23, 25-45, 25-47, and 25-48, in addition to CFTC Letter No. 25-44.20 Titan and Olympus make
the following representations:

• Titan will require that all Titan Contracts be fully collateralized;

• Titan will clear the Titan Contracts only through QC or Olympus;

• Titan will publish on its website the following time and sales data for all Titan Contracts
transactions promptly after execution thereof: trade timestamp, contract, quantity, and
price (in USD);

• Titan shall provide the Commission with transactional information as described in
Commission Regulation 16.02;

• Titan and Olympus shall continue to comply with all swap reporting and recordkeeping
requirements of the CEA and Commission regulations, other than the Relevant
Regulations, including (without limitation) the applicable requirements of Parts 38 and 39
of the CFTC’s regulations (the “Required Records”); and

16 Public Law 111–203, 124 Stat. 1376 (2010).
17 7 U.S.C. § 1a(47).
18 Further Definition of “Swap,” “Security-Based Swap,” and “Security-Based Swap Agreement”; Mixed Swaps;
Security-Based Swap Agreement Recordkeeping, 77 Fed. Reg. 48207, 48236 (Aug. 13, 2012).
19 Request at 1 n.1.
20 See Request at 5; see infra n.21.
38 and 39
of the CFTC’s regulations (the “Required Records”); and

16 Public Law 111–203, 124 Stat. 1376 (2010).
17 7 U.S.C. § 1a(47).
18 Further Definition of “Swap,” “Security-Based Swap,” and “Security-Based Swap Agreement”; Mixed Swaps;
Security-Based Swap Agreement Recordkeeping, 77 Fed. Reg. 48207, 48236 (Aug. 13, 2012).
19 Request at 1 n.1.
20 See Request at 5; see infra n.21.

4

• Titan and Olympus shall keep the Required Records open to inspection upon request by
any representative of the Commission, the United States Department of Justice, the
Securities and Exchange Commission, or by any representative of a prudential regulator as
authorized by the Commission. Copies of all such records shall be provided at the expense
of the producing party (Titan or Olympus) to any representative of the Commission upon
request. The producing party (Titan or Olympus) shall provide copies of the Required
Records either by electronic means, in hard copy, or both, as requested by the Commission,
with the sole exception that copies of records originally created and exclusively maintained
in paper form may be provided in hard copy only.

No-Action Position and Related Conditions

The Divisions have decided to take a no-action position consistent with the Request,
subject to certain conditions described below, based on Titan and Olympus’s representations and
statements in support of the Request. The Divisions note that this no-action position is similar to
previous no-action positions taken with respect to reporting certain binary options transactions and
similar
transactions.21

Pursuant
to
this
letter
and
CFTC
Letter
No
nt with the Request,
subject to certain conditions described below, based on Titan and Olympus’s representations and
statements in support of the Request. The Divisions note that this no-action position is similar to
previous no-action positions taken with respect to reporting certain binary options transactions and
similar
transactions.21

Pursuant
to
this
letter
and
CFTC
Letter
No.
25-44,
the Divisions will not recommend that the Commission initiate an enforcement action against
Titan, QC, Olympus, or their participants with respect to Titan Contracts for failure to comply
with: Commission regulations 38.8(b), 38.10, 38.951 (only to the extent that regulation 38.951
requires compliance with Part 45 of the Commission’s regulations), 39.20(b)(2), the applicable
provisions of Parts 43 and 45, or CEA provisions pursuant to which the Relevant Regulations were
promulgated. The no-action position includes the following conditions:22

21 See CFTC Letter No. 17-31 (June 30, 2017), available at https://www.cftc.gov/csl/17-31/download; CFTC Letter
No. 17-32 (June 30, 2017), available at https://www.cftc.gov/csl/17-32/download; CFTC Letter No. 21-11 (Apr. 22,
2021), available at https://www.cftc.gov/csl/21-11/download; CFTC Letter No. 24-09 (July 12, 2024), available at
https://www.cftc.gov/csl/24-09/download;
CFTC
Letter
No.
24-12
(Sept.
3,
2024),
available
at
https://www.cftc.gov/csl/24-12/download;
CFTC
Letter
No.
24-15
(Oct.
4,
2024),
available
at
https://www.cftc.gov/csl/24-15/download;
CFTC
Letter
No.
25-02
(Jan.
31,
2025),
available
at
https://www.cftc.gov/csl/25-02/download;
CFTC
Letter
No.
25-23
(Jul.
22,
2025),
available
at
https://www.cftc.gov/csl/25-23/download;
CFTC
Letter
No.
25-26
(Aug.
7,
2025),
available
at
https://www.cftc.gov/csl/25-26/download;
CFTC
Letter
No.
25-28
(Sept.
3,
2025),
available
at
https://www.cftc.gov/csl/25-28/download;
CFTC
Letter
No.
25-35
(Sept
),
available
at
https://www.cftc.gov/csl/25-02/download;
CFTC
Letter
No.
25-23
(Jul.
22,
2025),
available
at
https://www.cftc.gov/csl/25-23/download;
CFTC
Letter
No.
25-26
(Aug.
7,
2025),
available
at
https://www.cftc.gov/csl/25-26/download;
CFTC
Letter
No.
25-28
(Sept.
3,
2025),
available
at
https://www.cftc.gov/csl/25-28/download;
CFTC
Letter
No.
25-35
(Sept.
30,
2025),
available
at
https://www.cftc.gov/csl/25-35/download;
CFTC
Letter
No.
25-44
(Dec.
11,
2025),
available
at
https://www.cftc.gov/csl/25-44/download;
CFTC
Letter
No.
25-45
(Dec.
11,
2025),
available
at
https://www.cftc.gov/csl/25-45/download;
CFTC
Letter
No.
25-47
(Dec.
11,
2025),
available
at
https://www.cftc.gov/csl/25-47/download;
CFTC
Letter
No.
25-48
(Dec.
11,
2025),
available
at
https://www.cftc.gov/csl/25-48/download;
and
CFTC
Letter
26-01
(Jan.
8,
2026),
available
at
https://www.cftc.gov/csl/26-01/download.
22 Some of these conditions regarding the no-action position may constitute a collection of information, as that term
is defined in the Paperwork Reduction Act, 44 U.S.C. §§ 3501 et. seq. The Office of Management and Budget
(“OMB”)—in accordance with 44 U.S.C. § 3507(d) and 5 C.F.R. §§ 1320.8 and 1320.10—has approved collection
3038-0049, entitled “Procedural requirements for requests for interpretative, no-action and exemptive letters,” for
such purposes. This collection would encompass collections made as part of exemptive or no-action position from the
Commission or its staff. The public is not required to respond to a collection of information that does not have a valid
OMB control number.
approved collection
3038-0049, entitled “Procedural requirements for requests for interpretative, no-action and exemptive letters,” for
such purposes. This collection would encompass collections made as part of exemptive or no-action position from the
Commission or its staff. The public is not required to respond to a collection of information that does not have a valid
OMB control number.

5

1)
Titan will require all Titan Contracts to be fully collateralized positions, as defined
by Commission regulation 39.2;23

2)
Titan will clear all Titan Contracts through QC or Olympus and QC or Olympus
will clear all Titan Contracts;

3)
Titan will publish on its website the following time and sales data for all Titan
Contract transactions promptly after execution thereof: trade timestamp, contract,
quantity, and price;

4)
Titan will provide the Commission with all transactional information as described
in Commission regulation 16.02;

5)
Titan, QC, and Olympus will comply with all reporting and recordkeeping
requirements of the CEA and CFTC regulations applicable to them in their
respective capacities as a DCM and a DCO, other than the Relevant Regulations,
including, but not limited to, the applicable requirements of Parts 38 and 39 of the
Commission’s regulations (the records required to be retained by this condition (5)
are referred to below as the “Required Records”); and

6)
Titan, QC, and Olympus will keep the Required Records open to inspection upon
request by any representative of the Commission, the United States Department of
Justice, or the Securities and Exchange Commission, or by any representative of a
prudential regulator as authorized by the Commission. Copies of all such records
shall be provided, at the expense of Titan, QC, and Olympus, to any representative
of the Commission upon request
ired Records open to inspection upon
request by any representative of the Commission, the United States Department of
Justice, or the Securities and Exchange Commission, or by any representative of a
prudential regulator as authorized by the Commission. Copies of all such records
shall be provided, at the expense of Titan, QC, and Olympus, to any representative
of the Commission upon request. Titan, QC, and Olympus shall provide copies of
the Required Records either by electronic means, in hard copy, or both, as requested
by the Commission, with the sole exception that copies of records originally created
and exclusively maintained in paper form may be provided in hard copy only.

23 Commission regulations define “fully collateralized position” as “a contract cleared by a derivatives clearing
organization that requires the derivatives clearing organization to hold, at all times, funds in the form of the required
payment sufficient to cover the maximum possible loss that a party or counterparty could incur upon liquidation or
expiration of the contract.” 17 C.F.R. § 39.2.

6

This letter expresses a staff position only with respect to enforcement of the Relevant
Regulations. This letter does not state any legal conclusion regarding the characteristics or legality
of Titan Contracts or the conduct of any person covered by the no-action position.24 This letter
and the no-action position taken herein represent the views of the Divisions only, and do not
necessarily represent the positions or views of the Commission or of any other Commission
division or office. This letter and the no-action position taken herein are not binding on the
Commission.25 Except as explicitly provided in this letter, the no-action position taken herein does
not excuse persons from compliance with any applicable requirements of the CEA or Commission
regulations
ot
necessarily represent the positions or views of the Commission or of any other Commission
division or office. This letter and the no-action position taken herein are not binding on the
Commission.25 Except as explicitly provided in this letter, the no-action position taken herein does
not excuse persons from compliance with any applicable requirements of the CEA or Commission
regulations.

Further, this letter, and the no-action position contained herein, are based upon the
representations made to the Divisions, including the representations made by Titan and Olympus
that are described herein. Any different, changed, or omitted material facts or circumstances may
render this letter void. To the extent this Supplemental Staff Letter modifies CFTC Letter No. 25-
44, the no-action position provided in this letter supersedes CFTC Letter No. 25-44. In all other
respects, CFTC Letter No. 25-44 continues to be in effect. As with all no-action letters, the
Divisions retain the authority to, in their discretion, further condition, modify, suspend, terminate
or otherwise restrict the terms of the no-action position provided herein. This letter will expire at
the time that the Commission adopts amendments to its regulations that address event contract
reporting.

If you have any questions concerning this letter, please contact Paul Chaffin, Division of
Market Oversight, at (202) 418-5185 or pchaffin@cftc.gov; Alicia Silverman, Division of Market
Oversight, at (202) 418-5219 or asilverman@cftc.gov; Isabella Bergstein, Division of Market
Oversight, at (202) 993-1384 or ibergstein@cftc.gov; Owen Kopon, Division of Market Oversight,
at (202) 418-5360 or okopon@cftc.gov; or Daniel O’Connell, Division of Clearing and Risk, at
haffin, Division of
Market Oversight, at (202) 418-5185 or pchaffin@cftc.gov; Alicia Silverman, Division of Market
Oversight, at (202) 418-5219 or asilverman@cftc.gov; Isabella Bergstein, Division of Market
Oversight, at (202) 993-1384 or ibergstein@cftc.gov; Owen Kopon, Division of Market Oversight,
at (202) 418-5360 or okopon@cftc.gov; or Daniel O’Connell, Division of Clearing and Risk, at
(202) 418-5583 or doconnell@cftc.gov.

Sincerely,

____________________
Joshua Beale
Acting Director
Division of Market Oversight

____________________
Richard Haynes
Acting Director
Division of Clearing and Risk

24 For the avoidance of doubt, this letter is not intended to address whether any of the Titan Contracts are consistent
with any statutory or regulatory requirement, including with respect to the requirements of CEA section 5c(c)(5)(C)
or Commission regulation 40.11. 17 C.F.R. § 40.11.
25 See 17 C.F.R. § 140.99(a)(2) (“A no-action letter binds only the issuing Division . . . and not the Commission or
other Commission staff.”).

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---

Source: Frix Law Library, https://www.frixlaw.com/law-library/statutes/CFTC_L26_12. Check the current official text before relying on it. Not legal advice.