Comment on CFTC-2026-1189, CFTC-2026-1189-0001, Brubaker Public Relations, Inc.
Brubaker Public Relations, Inc.SupportBusiness
Summary: Steven G. Brubaker, writing as an individual with professional experience in gaming law, supports the proposed rule but argues it contains a structural gap regarding contract design. He urges the Commission to adopt specific disclosure requirements for market maker identities and financial relationships with contract designers to prevent undisclosed "structural holds" in multi-leg combo contracts.
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