CME Groupreason 01 of 4it owns a thing that cannot be built or permitted twicederived 2026-09-01accession 0001156375-26-000047
CME owns the dominant clearing infrastructure for futures across interest rates, equities, energy, agriculture, and metals — asset classes where open-outcry legacy and CFTC authorization create regulatory moats that competitors cannot replicate. Designation as a systemically important financial market utility cements its role as essential infrastructure, limiting new entrants.
the thesis · admitted · the reason above is the thesis, not printed twice
no findingread · nothing bore on it
It held on this filing. No finding was written because nothing in it bore on the reason — the sentences it was read against are below.
the evidence · every sentence checkedfour sentences · whole, uncut
the claims it rests on
“Contract volume and average rate per contract disclosures below exclude trading volume for event contracts, the cash markets business as well as interest rate swaps”
“Trading products represent futures and options products acquired in our business combinations with CBOT Holdings, Inc., NYMEX Holdings, Inc. and The Board of Trade of Kansas City, Missouri, Inc.”
“Product authorizations from the CFTC have no term limits”
“CME has been designated as a systemically important financial market utility by the Financial Stability Oversight Council”