Comment on CFTC-2026-1321, CFTC-2026-1321-0001, ProphetX LLC

Summary: ProphetX LLC, a recently registered DCM and DCO, supports the Commission's efforts to facilitate fintech innovation and requests the establishment of a conditional, class-based exemption from introducing broker (IB) registration for "Qualified Technology Service Vendors" (TSVs) facilitating access to sports event contracts. They argue that the current reliance on individualized no-action letters creates regulatory uncertainty and that a class-based exemption would provide the necessary clarity for market operators and technology providers to invest in compliant infrastructure.