The CFTC hasn't even finalized its sports event contract rules, and lawyers are already warming up for the sequel. Gaming attorney Daniel Wallach highlighted language from New York's court filing suggesting states are prepared to challenge any final rule in federal court, arguing the agency has exceeded its statutory authority and acted "arbitrarily and capriciously" under the Administrative Procedure Act. Translation: even if the CFTC gets its rule over the finish line, don't expect anyone to start celebrating just yet. 

The @NewYorkStateAG signals that the States will be challenging the CFTC's rulemaking on sports-event contracts (once finalized) in federal court as a violation of the APA because the CFTC is acting arbitrarily and capriciously and in excess of the statutory authority. https://t.co/hJFEZ0cVUR

A newly spotted self-certification filing by Aristotle Exchange (Underdog's CFTC-regulated exchange) appears to describe a contract that pays out only if all of several previously certified event contracts occur—in other words, something that looks remarkably like a parlay. The filing doesn't use the word "parlay," but the structure is hard to miss.

looks like Underdog self-certified parlays pic.twitter.com/8wohJ4WIBV