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Comment for Proposed Rule 91 FR 12516

  • From: Emily Zucca
    Organization(s):
    I am a member of the Cassandra Association and a supporter of Cassandra Laboratories Foundation, Inc.

    Comment No: 115278
    Date: 4/28/2026

    Comment Text:

    I work in data analytics focused on fraud, waste, and abuse, with experience in anti-money
    laundering, anti-corruption compliance, and internal controls across multiple industries. In that
    work, a core challenge is identifying meaningful signals from fragmented and often incomplete
    data. Event contracts perform a similar function in a different context: they aggregate
    dispersed information into a single probabilistic signal that can be used to inform decisions.
    That kind of forward-looking signal is not speculative in the abstract—it is operationally useful
    in environments where uncertainty is high and timing matters.

    In my experience, traditional monitoring systems tend to rely on lagging indicators. By the time
    a risk is clearly observable in structured reporting, the opportunity to intervene early has often
    passed. Approaches that incorporate probabilistic assessments—drawing on diverse,
    independent inputs—improve the ability to detect and respond to emerging risks. Prediction
    markets operate on that same principle. They synthesize distributed knowledge into a
    continuously updated signal, which can improve how organizations interpret uncertainty and
    allocate attention and resources.

    From that perspective, event contracts can contribute to the functions described in § 3(a),
    particularly price discovery and the dissemination of pricing information. When designed
    around research or policy-relevant questions, they generate timely information about
    uncertain future states in a way that is directly relevant to risk management. Treating these
    mechanisms solely through the lens of traditional commodity hedging misses the broader
    informational role they can play.

    From an operational standpoint, markets designed to generate information for research and
    decision-making serve a different function than commercial trading platforms, and evaluating
    them the same way risks overlooking their distinct value.