Comment on CFTC-2026-1189, CFTC-2026-1189-0001, Reifi, Inc.

Summary: Reifi, Inc. opposes the categorical classification of "Player injury contracts" as contrary to the public interest, arguing that their specific OTC swap products are distinct from retail prediction markets. They argue these swaps are necessary for professional sports teams to hedge business risks and request that the Commission allow these specific contracts to be listed and cleared on registered Swap Execution Facilities.