The Gap
Sponsors have no regulated mechanism to offload performance-linked liability.
· Earnings structures transfer incentives — not risk.
· There is no regulated instrument to transfer what remains.
Sponsors bear the exposure with no mechanism to hedge it.
We're building the performance risk transfer market.
Timeline
Validation
Milestone
Supplemental comment filed. Confidential regulatory filings in preparation
May 2026
Market viability confirmed from a Senior marketing professional, major Olympic sponsorship services organization, for a regulated and accessible performance liability hedging instrument
Q2 2026
Professional validation from a Senior Finance Leader, major global multi-sport sponsor, of a valid use case for a regulated and accessible performance liability hedging instrument
Q2 2026
Confirmed by the Chief Executive of a multi-sport equipment and apparel brand with active or in-development performance-contingent athlete sponsorships in professional tennis, pickleball, padel, and others, that current exposure is carried on the balance sheet using actuarial estimation, with insurance products only commercially viable in higher-value sport categories — and stated interest in a regulated hedging instrument
Q2 2026
Confirmed by a Senior executive, professional racket sport equipment and apparel brand with active athlete sponsorships, that performance-contingent commercial terms create unhedged balance sheet exposure — and stated interest in a regulated hedging instrument
Q2 2026
Confirmed by an NFLPA Certified Contract Advisor and attorney with over two decades representing professional athletes that no standardized, regulated instrument exists for commercial counterparties to hedge performance-contingent athlete exposure
Q2 2026
ANPR published (91 FR 12516), opening a 45-day comment period. Staff Advisory on single-actor event contracts incorporated into framework
Mar 2026
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Concept validated across multiple single-sport corporate sponsors
Q1 2026
Commission Chairman addresses industry conference, solidifying a principles-based oversight posture for prediction markets
Feb 2026
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Incoming Commission leadership withdraws 2024 rule prohibiting sports event contracts. Inaugural address signals clear rules for prediction markets under DCM framework
Jan 2026
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Concept development initiated
Q4 2025
CFTC leadership transition signals potential shift from prohibitive framework toward principles-based oversight of prediction markets
Q4 2025
Problem identified: a performance-based sponsorship agreement produced an unhedgeable liability with no regulated mechanism for transfer, resulting in material unplanned exposure on the balance sheet
Q4 2023