Comment Text:
As someone who has nothing to gain or lose from the decision on this issue, I am commenting as a true member of the public. I am against approving the proposed futures contracts.
1. Of course, these contracts would involve, relate to, or reference "gaming". The true description of the underlying activity that would be hedged is "gambling".
2. Federal law and many states' laws prohibit gambling on sports. So, of course, the proposed futures contracts would, then, involve, relate to, or reference an unlawful activity.
3. If there were a need for vendors and/or stadium owners to hedge their businesses, they would have requested it many years ago and not wait until the legalization of gambling on sports in their respective states. I believe that money-laundering would increase if the proposed futures contracts were approved. The participation restrictions are irrelevant because the proposed futures contracts involve, relate to, or reference an unlawful activity. Federal law and many states' laws prohibit gambling on sports for the very reason that it is contrary to the public interest.
4. A decision on approving the proposed futures contracts should be delayed until the underlying gambling on sports is approved in all states. I hope that never happens.
5. I believe that approval of the proposed futures contracts would create an incentive to influence the outcome of sporting events. A decision on approving the proposed futures contracts should be delayed until a history is available of attempts to influence the outcome of sporting events that occur after the legalization of gambling on sports. A review of that history would determine what mechanisms would best work to surveil for, and guard against, manipulation of these contracts through manipulation of the outcome of sporting events.
6. The Commission should consider that the underlying activity of gambling on sporting events is an addictive activity. The Commission should consider the thousands and thousands of unknown gambling addicts and the unheard victims of gambling-related crimes. The Commission should consider the increased marketing of gambling to the public, the increased acceptance of gambling by the public, and the increased harm of gambling to the public and, especially, to children. The Commission should consider that many public comments are from those who would benefit financially from the proposed futures contracts. The Commission should consider that very few members of the public know about the opportunity to express their views on this issue to you. This Commission should consider the conclusions of the National Gambling Impact Study Commission.
