Prediction Markets; Public Interest Determinations - Proposed Rules

Jim Bob Morris, founder of Wanna.com and Wanna Parlay, supports the proposed action to strictly enforce public interest determinations against binary sports event contracts. He argues that allowing these contracts would create a loophole for regulatory arbitrage, undermining state gaming laws, tribal sovereignty, and the competitive standing of law-abiding operators.

Oregon Consumer Justice opposes the proposed rule, arguing that it prioritizes market expansion and profit over necessary consumer protections against the risks of gamified prediction markets. The organization advocates for more robust policies, vigorous enforcement of existing laws, and collaboration with other federal and state agencies to protect retail users from financial harm and addiction.

PinHigh Sports LLC submits a comment in support of the proposed rules regarding prediction markets. The company argues that the rules provide necessary clarity and oversight while protecting the integrity of the markets and the interests of participants.

Reifi, Inc. opposes the categorical classification of "Player injury contracts" as contrary to the public interest, arguing that their specific OTC swap products are distinct from retail prediction markets. They argue these swaps are necessary for professional sports teams to hedge business risks and request that the Commission allow these specific contracts to be listed and cleared on registered Swap Execution Facilities.

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.

Primev, represented by its CEO, supports the Commission's proposed rules for prediction markets, praising the focus on underlying events over trading acts. They suggest specific clarifications regarding "discrete-action" factors, objective settlement data, and the treatment of fast-settling contracts to ensure the rules do not overreach while maintaining market integrity.

Devin Darmody, an individual trader, supports the proposed rule because it maintains a contract-by-contract review process and recognizes that banning contracts may drive users to unregulated offshore markets. He argues that regulated domestic exchanges provide necessary protections and useful price discovery for mainstream sports markets.

Alex Russell, a finance professional and prediction market user, supports the proposed rule while urging the CFTC to maintain a contract-by-contract review process. He argues that keeping these markets on regulated exchanges is safer than driving users to offshore platforms and emphasizes the value of price discovery and information.

Stevie Mallia, an individual trader, supports the proposed rule for reviewing prediction market contracts on an individual basis rather than banning entire categories. The commenter argues that this approach provides transparency, prevents the displacement of trading to offshore sites, and recognizes the information value of market prices.

Gaven Anguiano, a sports trader, supports the proposed rule because it allows for individual contract reviews and recognizes the public interest of price discovery. He argues that clear regulations will keep trading on regulated U.S. platforms rather than pushing traders toward offshore markets with fewer protections.