Comment on CFTC-2026-1189, CFTC-2026-1189-0001, Quotient

Quotient submits this comment on the Commission's proposed rule concerning event contracts involving enumerated activities (RIN 3038-AF65, 91 FR 35806). Quotient is a forecasting and prediction markets research firm. We support the Commission's effort to bar contracts that pay out on war, terrorism, and assassination, and we submit market-level evidence on how the proposed rule would apply in practice. We read every active geopolitics market on Polymarket as of June 15, 2026, 879 contracts holding $633.4M in cumulative volume, and classified each by the event that makes it pay. Polymarket serves as the evidence base because it offers the largest live catalog of the contract types a CFTC-registered venue may seek to list. Our central finding is that the rule reaches a small share of markets but a large share of volume. Under a narrow reading, 84 percent of markets remain listable as written. Under a broad reading, that falls to 62 percent, and by volume the listable share falls from 52 percent to 31 percent. Approximately $125.5M sits in direct-attack markets that pay when a strike happens or a war starts. These match the Commission's central concern, and our recommendations preserve the Commission's ability to reach them. A further $128.5M changes status between the narrow and broad readings, concentrated in leader and regime survival, ceasefire and peace-deal markets, and territorial control. These are contracts where violence is one possible path to resolution among several peaceful ones, and they are where clarification would do the most work. We respectfully ask the Commission to clarify four points, developed fully in the attached letter. Publish safe-harbor model language for contracts whose outcomes can occur through both enumerated and non-enumerated mechanisms. Model wording takes a contract out of the rule's scope entirely, so the public-interest determination never reaches it. Define the line for diplomatic-status markets, confirming that contracts settling on signed agreements, normalization, or recognition settle on diplomatic acts rather than acts of war. Separate violent acts from measurements, distinguishing contracts that settle on an attack from contracts that settle on a price, count, or status determination that conflict may affect. Publish the criteria the Commission will apply in the public-interest determination for contracts that remain in scope, so venues have predictability beyond drafting. Across all four, one principle controls. Apply the rule to the settlement-determining occurrence rather than the background cause. Attached are our full comment letter, the complete report, the row-level classification of all 879 markets, and our classification rulebook and validation materials. We would be pleased to provide any further supporting data. Respectfully submitted, Shira Stember and Jordan Olmstead, Co-Founders, Quotient