Comment Text:
In response to the Commission's request for public comment, I'm submitting the attached analysis: "Proposed CFTC Event Contract Rule Creates Uncertainty, Could Stifle Markets with Consequential Commercial Value" by Ryan Hayden, Micah S. Green, Alexandra C. Scheibe, Richard Shilts, Michael V. Dunn of Steptoe LLP. The article walks through the negative consequences of the proposed rule.
The authors and the law firm are not party to this comment.