What it means when a DFS platform stops routing through Kalshi or CDNA and starts operating its own CFTC-licensed exchange.
Exchange Type
DCM + DCO
FCM
UDM LLC
DCM Reg. Date
Sep 5, 2025
UDX Launch
Jul 17, 2026
The key takeaway from this page
Two Different Products
UDX is Underdog's prediction market exchange (launched July 2026, built on Aristotle Exchange DCM/DCO infrastructure acquired March 2026). The Underdog Predict service — which routed trades through CDNA — is the legacy product. For a full review of the legacy platform, fees, and state availability see the Underdog Guide.
CFTC DCM + DCO
Aristotle Exchange DCM, Inc. + DCO, Inc. — registered Sept 5, 2025
UDM LLC (Underdog Predict)
NFA-registered Futures Commission Merchant, Jan 9, 2026
July 17, 2026
CEO Jeremy Levine announced on CNBC. Verify at underdogfantasy.com.
Game-winner · Winning-margin · Total-score
Sports event contracts only at launch; NFL expansion announced.
$0.02/contract
UDX fee structure pending confirmation. Verify at underdogfantasy.com.
49 states + DC
Overall Underdog platform per underdogfantasy.com. UDX-specific states: confirm on site.
Underdog UDX is the self-operated prediction market exchange that Underdog Sports Holdings launched in July 2026. The name "UDX" refers to the exchange product running on infrastructure Underdog acquired from Aristotle Exchange on March 9, 2026. Unlike the earlier Underdog Predict service — which executed trades through CDNA (Crypto.com Derivatives North America) as a technology service provider — UDX is built on acquired Aristotle Exchange DCM and DCO infrastructure — CFTC-registered entities that Underdog purchased on March 9, 2026, giving it its own exchange and clearinghouse for event contracts.
The exchange was announced by CEO Jeremy Levine on CNBC on July 17, 2026. Initial contracts at launch cover sports categories using CFTC-certified contract types: game-winner, winning-margin, and total-score markets. Multi-leg contracts combining outcomes via AND/OR logic are also supported. NFL season market expansion was announced at launch.
All contracts are structured as binary event contracts: positions resolve at either $0 (wrong) or $1.00 (correct), making them fundamentally different from traditional sportsbook wagers: positions resolve at either $0 (wrong) or $1.00 (correct), regardless of how familiar the underlying sport category may appear.
UDX sits within a three-entity regulatory stack — all under CFTC jurisdiction:
The Designated Contract Market: CFTC-registered exchange that lists and rules on event contracts. CFTC registration effective September 5, 2025; acquired by Underdog on March 9, 2026 (Business Wire). New contracts must be self-certified or Commission-reviewed before listing — the same requirement that applies to Kalshi.
The Derivatives Clearing Organization: the entity that guarantees and settles trades. By owning the DCO, Underdog controls settlement timing and can custody user funds without a third-party clearinghouse. CFTC registration also effective September 5, 2025; same acquisition date as the DCM.
The Futures Commission Merchant: accepts customer orders and routes them to the exchange. NFA-registered as FCM and swap firm since January 9, 2026 (NFA BASIC registry). The FCM entity holds user accounts and executes trades on behalf of customers.
PredictIt Is Separate
PredictIt was not included in the Aristotle Exchange acquisition. PredictIt continues to operate under Aristotle Company's CFTC no-action letter. UDX and PredictIt share no operational connection.
Underdog is the third major DFS platform to exit third-party exchange infrastructure and self-operate within roughly 12 months. All three moved from third-party execution agreements to fully licensed, self-operated DCM + DCO stacks:
| Platform | Exchange | Timing | Detail |
|---|---|---|---|
| DraftKings | DKeX (own DCM/DCO) | 2026 | DraftKings exited CDNA to operate DKeX independently; NFA FCM upgrade pending. |
| Robinhood | Rothera Exchange & Clearing LLC | Jan 2026 | CFTC name-change order Jan 20, 2026; self-operated DCM + DCO. |
| Underdog | UDX (Aristotle DCM/DCO) | Jul 2026 | Acquired Aristotle Exchange Mar 9, 2026; launched UDX in July 2026. |
The common thread: all three platforms built their user bases through DFS and Pick'em products before investing in exchange infrastructure. Owning a DCM lets them control which contracts they can list, how they settle, and what they charge — without platform fees flowing to a third-party exchange.
The legacy Underdog Predict product charged $0.02 per contract (flat fee, built into the entry price), with free deposits and withdrawals. UDX may introduce a different fee structure — confirm the current schedule at underdogfantasy.com .
Source for legacy fee: https://help.underdogfantasy.com. UDX fee: pending verification.
Both UDX and Kalshi are fully self-operated CFTC DCM + DCO stacks — but they serve very different user segments:
| Dimension | Underdog UDX | Kalshi |
|---|---|---|
| Regulatory status | CFTC DCM + DCO (Aristotle); FCM (UDM LLC) | CFTC DCM (Kalshi Inc.); DCO (Kalshi Klear LLC) |
| Origin | DFS-first (Pick'em / Fantasy) | Purpose-built prediction market exchange |
| Market scope | Sports contracts only at launch | Sports, politics, economics, finance, climate, and more |
| Contract format | Game-winner, winning-margin, total-score; multi-leg AND/OR logic | Binary event contracts across all categories |
| User base fit | Existing Underdog DFS users | Prediction market specialists, traders, researchers |
| Self-clearing | Yes (via Aristotle DCM/DCO) | Yes (Kalshi Inc. + Kalshi Klear) |
The practical difference for traders: Kalshi offers the broadest market variety, including political and economic events. UDX is built for sports, designed to pull in the existing Underdog DFS audience with familiar contract vocabulary (spread, total, moneyline).
All factual claims on this page trace to primary or authoritative sources. Where pending verification is noted, confirm details directly with the platform.
UDX is one of several CFTC-regulated options. Compare fees, markets, and state access across all platforms.
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