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Both filings landed on the same day. One of them was not a proposal at all but thirty-plus separately docketed contracts, including one on a real estate investment trust. And neither takes effect unless the Commission affirmatively approves it.
The Commodity Futures Trading Commission's public Designated Contract Market Products listing carries a record of the filings that would bring perpetual futures on individual United States stocks to regulated American venues. Three things in that record differ materially from the widely circulated account of it.
One: the same day, not a day apart
Under organization code COIN, the listing carries a product titled "Single Stock Perpetual Futures Contract," type Future, dated , categorized as a Security Futures Product with subcategory single stock future, and attaching a document titled "2026-62 Listing of Security Futures Product_41.23(b)."
Under organization code KEX, the listing carries its entries dated as well. The same date. Both sets of filings carry the same document URL prefix.
The account in circulation dates the second filing to and frames it as an answer to the first. The Commission's own record does not support that sequencing. The two arrived simultaneously, which strengthens rather than weakens the competitive reading but changes the story from a response to a collision.
Two: not a proposal, thirty-plus contracts
The KEX entries are not a single filing. They are individually docketed perpetual futures products named per underlying ticker, all dated and all at status "Approval Pending (45)."
Thirty were verified directly from the listing: AAPLPERP, ABBVPERP, ADBEPERP, AMATPERP, BRKBPERP, JNJPERP, JPMPERP, KOPERP, LLYPERP, LMTPERP, MAPERP, MCDPERP, METAPERP, MRKPERP, MSFTPERP, MUPERP, NEMPERP, NFLXPERP, NVDAPERP, ORCLPERP, PANWPERP, PEPPERP, PFEPERP, PGPERP, PLDPERP, PLTRPERP, QCOMPERP, SBUXPERP, SNDKPERP and SPCXPERP. Further tickers appear beyond the verified portion of the listing.
One of those thirty is not a stock. PLDPERP is subcategorized as a real estate investment trust rather than a single stock future. A perpetual future on a REIT is a distinct product with distinct distribution and tax characteristics, and it appears nowhere in the public discussion of these filings.
Three: approval requests, not self-certifications
Both organizations' filings carry the status "Approval Pending (45)."
That distinction is load-bearing and it is the single most important thing in the record. A self-certification under the Commission's rules takes effect automatically unless the Commission acts to stop it. An approval request does the opposite. Nothing launches unless the Commission affirmatively says yes, on a 45-day clock, extendable.
The reported version of these filings implies a competitive scramble toward a product arriving by default. The record describes two simultaneous, highly granular approval requests sitting in front of a regulator that has to act for anything to happen at all.
The litigation overhang
That regulator is being sued over the question underneath all of it. A federal case challenging the legal classification of perpetual futures under the Commodity Exchange Act remains pending before Judge Colleen Kollar-Kotelly, with an opposition brief due and no ruling issued.
If a court determines that a perpetual contract is not a future within the statutory definition, the entire product category's regulatory home becomes an open question, regardless of what the Commission does with these applications.
A caveat on identity
The Commission's listing publishes organization codes, not legal entity names. That COIN corresponds to Coinbase's derivatives entity and KEX to Kalshi's exchange entity is an identification drawn from public reporting rather than from the Commission's own record, which does not expand the codes.
Contract mechanics reported for the COIN product, including a 0.01 share contract size and a funding rate cap, have not been confirmed against the Commission's record and should be treated as unconfirmed.
What to watch
The 45-day clock from runs to early November. The first concrete development would be either Commission action on any single one of these contracts or an extension of the review period. The briefing deadline in the pending litigation is the other dated catalyst.