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Stephen C. Piepgrass

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Stephen leads the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group. He focuses his practice on enforcement actions, investigations, and litigation. Stephen primarily represents clients engaging with, or being investigated by, state attorneys general and other state or local governmental enforcement bodies, including the CFPB and FTC, as well as clients involved with litigation, with a particular focus on heavily regulated industries. He also has experience advising clients on data and privacy issues, including handling complex investigations into data incidents by state attorneys general other state and federal regulators. Additionally, Stephen provides strategic counsel to Troutman Pepper’s Strategies clients who need assistance with public policy, advocacy, and government relations strategies.

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In this crossover episode of Payments Pros and Regulatory Oversight, Stephen Piepgrass and Keith Barnett provide an update on the fast-developing prediction markets landscape. They discuss how federal and state regulators are responding to the growth of event contracts and the legal questions surrounding this emerging market. The conversation highlights the CFTC’s continued focus on oversight, market integrity, and the need for platforms to maintain strong controls to detect and prevent manipulation or other improper trading activity.

In this episode of Regulatory Oversight, co-host Stephen Piepgrass sits down with Jay Dubow and Ghillaine Reid, co-leaders of the firm’s Securities Investigation + Enforcement practice, to explore how the SEC’s enforcement agenda is evolving under Chairman Paul Atkins and what that means for public companies, financial institutions, and their executives.

In this episode of Regulatory Oversight, host Stephen Piepgrass is joined by his new colleague Jason Smith, a veteran Senate lawyer and strategist who spent more than 15 years on Capitol Hill. Jason’s tenure includes advising Senators John Fetterman, Patty Murray, and Mark Begich on high-stakes issues ranging from voting rights and immigration reform to pharmaceutical policy and international trade.

This article was originally published in Dow Jones Risk Journal and is republished here with permission as it originally appeared on May 4, 2026.

Prediction markets allow users to trade event contracts on real-world events, such as election outcomes, sporting events and even the highest temperature in New York City today. Seemingly overnight, they have achieved mainstream prominence. Since 2025, Kalshi’s user base alone has grown from approximately 600,000 to more than 5,000,000.

On March 11, Kalshi filed a lawsuit in the U.S. District Court for the Southern District of Iowa against Attorney General (AG) Brenna Bird and members of the Iowa Racing and Gaming Commission. Kalshi’s complaint asks the court to declare that the Commodity Exchange Act (CEA) and the Commodity Futures Trading Commission’s (CFTC) “exclusive jurisdiction” over trading on designated contract markets preempt Iowa’s gambling and election‑wagering provisions as applied to Kalshi’s event contracts.

On March 12, 2026, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight issued Staff Advisory Letter No. 26-08 to all designated contract markets (DCMs), signaling a supportive stance toward prediction markets and other event-based derivatives, including contracts based on the outcome of sporting events. While reiterating existing compliance obligations, the advisory emphasizes the agency’s interest in fostering innovation and growth in these markets within the framework of the Commodity Exchange Act. At the same time, the CFTC released an advance notice of proposed rulemaking seeking broad public comment on whether and how to further regulate event contracts.

A recent decision from the U.S. District Court for the Middle District of Tennessee marks a significant development in the ongoing dispute over whether sports event contracts offered on prediction market platforms are properly regulated by the Commodity Futures Trading Commission (CFTC) or whether such contracts should be regulated by the states as sports betting. Tennessee officials had issued a cease‑and‑desist order contending that certain sports‑linked event contracts were akin to unlicensed sports wagering under state law. Prediction contract platform provider, Kalshi, responded by filing suit in federal court, arguing that these contracts were “swaps” governed exclusively by the Commodity Exchange Act and subject to the CFTC’s jurisdiction, not Tennessee’s sports‑betting framework.

In this special crossover episode of Regulatory Oversight and FCRA Focus, Kim Phan is joined by Michael Yaghi, partner in Troutman Pepper Locke’s Regulatory Investigations, Strategy + Enforcement practice group, to unpack the California Department of Financial Protection and Innovation’s (DFPI) latest effort to require registration for the credit reporting industry. They discuss DFPI’s second request for comment, how it fits into California’s broader push to regulate nonbank financial services, and which entities may be swept in beyond the “big three” consumer reporting agencies — such as furnishers, data brokers, specialty credit reporting agencies, resellers, and fintechs. Kim and Michael also explore how narrowly (or broadly) the rules might be drawn, potential overlap and tension with existing FCRA requirements, what registration and reporting could mean in practice for covered entities, and what companies should be doing now as the February 26 comment deadline approaches.