---
type: source
title: "DLA Piper: Corporate Event Contracts Already Within Ordinary CFTC Scope — Merger Dates, Earnings Calls"
author: "DLA Piper (Market Edge)"
url: https://marketedge.dlapiper.com/2026/04/the-rise-of-prediction-markets-and-the-surrounding-regulatory-environment/
date: 2026-04-01
domain: internet-finance
secondary_domains: []
format: article
status: processed
processed_by: rio
processed_date: 2026-05-07
priority: medium
tags: [CFTC, event-contracts, corporate-events, prediction-markets, regulatory, insider-trading]
intake_tier: research-task
extraction_model: "anthropic/claude-sonnet-4.5"
---

## Content

DLA Piper's April 2026 article on prediction markets' regulatory environment explicitly acknowledges corporate event contracts as within ordinary scope.

**Key finding:** "a wide range of corporate events and activities could be the subject of an event contract (_e.g._, whether a company will complete a merger by a certain date or the number of times its chief financial officer says 'tariffs' during an earnings call)"

**Recommendation:** DLA Piper recommends public companies address insider trading risks for corporate event contracts.

**Scope of article:** Primarily focused on sports/election event contracts. Corporate event contracts are noted as an emerging concern for public companies. No blockchain, DAO, or governance market analysis.

**Section 5c(c)(5)(C) discussion:** Article discusses the CFTC's authority to prohibit "gaming" contracts, noting outer limits of Section 5c exclude "unlawful activities...gaming, terrorism, war, or other similar activities."

## Agent Notes

**Why this matters:** DLA Piper's acknowledgment that corporate event contracts are "ordinary scope" is a double-edged finding for MetaDAO. It confirms that practitioners already think about corporate governance events in prediction market terms. But the analysis is entirely aimed at traditional public companies with GAAP financials — not DAOs.

**What surprised me:** The specificity of the examples — "number of times his chief financial officer says 'tariffs' during an earnings call" is an extremely granular corporate event. If that's ordinary scope, then MetaDAO governance decisions (treasury deployment, project funding) could theoretically also be within scope. But DLA Piper doesn't make this connection.

**What I expected but didn't find:** Any mention of DAO governance, blockchain-based corporate events, or on-chain governance markets. Despite the broad framing of corporate event contracts, DLA Piper's regulatory lens remains fixed on traditional public companies.

**KB connections:**
- [[MetaDAO conditional governance markets may fall outside the CFTC event contract definition because TWAP settlement against internal token price is endogenous rather than an external observable event]] — the DLA Piper framing slightly challenges the claim that MetaDAO governance markets are categorically different; corporate event contracts are ordinary scope, so MetaDAO governance events could be swept in if a regulator is creative
- SEC company-specific event contract track (Cleary Gottlieb) — DLA Piper's corporate events analysis reinforces the SEC track's plausibility, though settlement mechanism still differs (TWAP vs. financial statements)

**Extraction hints:**
1. Note that this is evidence of SCOPE CREEP risk — practitioners are already expanding the event contract lens to corporate events beyond sports/elections. MetaDAO's non-traditional structure needs to be documented as specifically distinct.
2. Extractor should note this as evidence for the "why this gap persists" section of the endogeneity claim: practitioners ARE thinking about corporate event contracts, but haven't yet connected this to DAO governance markets.

**Context:** DLA Piper's Market Edge is a high-credibility practitioner publication. The April 2026 date is concurrent with the circuit split period.

## Curator Notes

PRIMARY CONNECTION: [[MetaDAO conditional governance markets may fall outside the CFTC event contract definition because TWAP settlement against internal token price is endogenous rather than an external observable event]]
WHY ARCHIVED: Evidence of practitioners already extending event contract scope to corporate events — creates context for why MetaDAO governance markets need explicit structural analysis
EXTRACTION HINT: Use as scope challenge evidence: if corporate event contracts are already in ordinary scope, MetaDAO governance events require affirmative structural differentiation, not just absence of analysis
