Comment on CFTC-2026-1453, CFTC-2026-1453-0001, Stellar Quanta Labs, LLC

Stellar Quanta Labs, LLC submits the attached comment on RIN 3038-AF73, Data Reporting Requirements for Certain Event Contracts. Stellar Quanta Labs is a small business that develops cryptographic provenance and temporal attestation infrastructure, including post-quantum implementations. The company is not registered with the Commission in any capacity, has not applied for any registration, and has no commercial relationship with any designated contract market, derivatives clearing organization, futures commission merchant, or other person subject to this proposal. The comment addresses two matters. First, Section 16.03(b). The Commission has stated that the settlement information requirement would benefit market participants by ensuring that the contract determination process is auditable. We support the requirement. An event contract differs from a conventional future in that it settles against a fact about the world, established by reference to a source the exchange does not operate, does not control, and does not retain. Sources change: the Bureau of Economic Analysis published three different values for fourth-quarter 2025 gross domestic product growth, and the figure ultimately published was approximately one third of the figure first published. As drafted, a reported source identifier and timestamp cannot distinguish a determination captured contemporaneously from one reconstructed afterward, and a designated contract market that determined a contract correctly has no means of demonstrating that it did. We recommend that the Commission permit, but not require, a reporting entity to accompany the settlement record with an integrity attestation binding the reported source material to the reported determination time, verifiable without reliance on the reporting entity's own systems. A permissive provision imposes no cost on entities that decline it and is satisfiable by existing non-proprietary approaches including ANSI X9.95, IETF RFC 3161, IETF RFC 4998, and ISO/IEC 18014. Second, Sections 16.03(g) and 16.03(h) and Regulation 1.31. Records retained for five years will remain within their required retention period at a time when the signature algorithms protecting their integrity are expected to be deprecated. Regulation 1.31(c)(2)(i) contemplates maintaining the signature as a component of record authenticity but does not address what happens when the signature algorithm itself is no longer approved. We recommend that the Commission address the cryptographic durability of long-retention records in the final rule or in accompanying guidance. The comment offers no view on the proposed reporting levels, the large trader thresholds, or the scope of the Covered Event Contract definition.