Legal & compliance posture

How Langbot is designed to stay on the right side of CFTC 26-25, venue agreements and recording law. Not legal advice.

Not legal advice. This page documents design rules we follow; counsel review is scheduled. See the Terms, Privacy and Risk disclosure.

CFTC Staff Letter 26-25 (Sep 17 2026)

No-action relief from IB registration for passive, non-custodial software that routes to DCMs, does not exercise trading discretion, does not generate buy/sell signals, and does not charge volume-based fees. Design rules:

Execution runs on the user's machine with the user's keys (langbot run, a local process on loopback).
Langbot emits facts ("‘tariff’ spoken at t"), not buy/sell signals.
Strategies are user-authored or user-approved; the LLM drafts, the user reviews and runs.
Flat pricing: $0 / $49 / $199 per month, or an annual Enterprise license. Never per trade or per volume.
Hosted agent execution is deferred until counsel reviews CTA exposure.

Kalshi Developer Agreement

API use is limited to a member's own trading and Kalshi data may not be redistributed. We use public market metadata (tickers, rules, schedules) to match markets to events and never resell order-book data. Anything account-related uses the user's own keys.

Rights, redistribution and retention

Langbot sells facts about what was said, not the expression. This is a product rule enforced in the feed, not only a policy on this page. Every source carries a rights class:

class	what it covers	what customers receive
`public_domain`	US federal proceedings: Congress, Fed press conferences, agency hearings, C-SPAN federal feeds	the full timestamped transcript and every event type
`licensed`	a written license from the rights holder or a licensed vendor feed, named on the source	the full transcript, as the license allows
`restricted`	issuer earnings calls, broadcaster feeds, anything under terms that bar redistribution	phrase facts only
`unknown`	the default until a source is classified	treated as `restricted`

Phrase facts only means: phrase_detected with the matched phrase, the speaker's role or label (never a verbatim quote), a confidence score, the three timestamps, the measured lead and the market tickers, plus speaker_change, event_started, event_ended, silence and source_status. No transcript_delta, and no text beyond the matched phrase. The phrase itself is the market's own term, taken from the venue's public rules text.

Retention:

Audio is never written to disk by our listeners; they work from in-memory buffers. Operations recordings are opt-in per run and expire with it.
For restricted sources, transcript words and text windows expire after the source's retention period (default 30 days). Phrase facts are kept indefinitely.
public_domain and licensed transcripts are kept.

Public domain is set only from an allowlist of federal sources; licensed only when a license is on record; everything else is restricted. We register under our real identity and never spoof. Swatch v. Bloomberg (2d Cir. 2014) held that republishing a recorded earnings call to subscribers was fair use, and Reg FD pushes calls to be open; we nonetheless treat issuer calls as restricted because the remaining risk is contractual (webcast terms, "do not record" notices) and wiretap consent in all-party-consent states.

No signals

Events never carry a direction, a recommendation or a price target. Base rates and mispricing in the history are summaries of the venue's settled record, not forecasts. The SDK's strategy runtime runs on the customer's machine under the customer's venue keys.

Venue history is public record

Settled mention markets (market_outcomes: ticker, rules, open and close prices, result, settlement time) are the venue's own published facts. Langbot redistributes them as fact on every plan, with a canonical speaker key and phrase key added for search.

Venue countermeasures

Kalshi Rule 13.1(i) allows order delays on live events; Polymarket runs 50 ms–3 s taker delays. Our value survives delays (reliability, breadth, archive, backtests); the latency edge shrinks, and the latency board says so honestly.

Insider risk

The CFTC fined a White House teleprompter operator for mention-market insider trading. We use only public broadcasts and document provenance for every source.

Entity and payments

Delaware C-corp before accepting payments. Stripe in test mode until then.