Comment Text:
Comment for Proposed Rule 91 FR 12516
April 30, 2026
Michael S. Selig
Chairman
Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street, NW
Washington, DC 20581
Dear Chairman Selig:
At Gambling is Not Investing, we are dedicated to a singular mission: ensuring that gambling products comply with established state and tribal laws and are never confused with legitimate financial investments. We represent a diverse group of consumer advocates and community leaders, united by the goal of removing sports event contractions from prediction markets.
We are deeply concerned that prediction markets are serving as a backdoor for unregulated sports gambling. By rebranding sports wagering as "trading" or "investing," these platforms encourage consumers to mistakenly treat a form of entertainment as a financial product. This deceptive labeling is not merely a matter of semantics; it has real-world consequences for individuals and families across America.
The rise of these markets also represents a direct assault on the state and tribal frameworks that govern legal gaming. State-regulated sports books are required to implement rigorous age and identity verification, responsible gaming tools, and integrity monitoring. Prediction markets bypass these critical safeguards, creating an environment where consumers are left vulnerable and underage gamblers can bypass state laws.
Furthermore, when wagering shifts outside of these established frameworks, communities lose out on essential public revenue. It is estimated that hundreds of millions of state gaming tax dollars have already been lost as a result of prediction markets offering sports event contracts.
The current landscape has effectively lowered the age for sports gambling from 21 to 18, exposing underage users to gambling-like behavior in a format that appears legitimate and accessible. When 18-year-olds can risk money to “predict” the outcome of a game that they cannot legally bet on in the same state, our concern should not be the semantic debate over prediction vs. betting. Our concern should be that the system isn’t working and consumers are left at risk.
Sports event contracts are sports bets. They do not serve a productive economic purpose like price discovery or hedging. Instead, they facilitate a high-stakes gambling environment that lacks the oversight necessary to protect the public interest.
The Gambling is Not Investing Coalition urges the CFTC to maintain the integrity of our financial markets by explicitly prohibiting sports event contracts. We must ensure that the line between investing and sports betting remains clear. Financial platforms should remain a space for building wealth and economic stability, not a venue for unregulated gambling disguised as innovation.
Sincerely,
Mick Mulvaney, Executive Director of Gambling is Not Investing
