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Comment for Proposed Rule 89 FR 48968

  • From: michael G. Colopy
    Organization(s):
    Self

    Comment No: 73839
    Date: 6/26/2024

    Comment Text:


    Dear Chairman Behnam,

    I am writing to you today as someone with a great love for commodities trading, a vibrant market that fosters immense economic agility and shapes global finance. The purpose of my letter is to dive into the contentious issue of election futures, and specifically, the recent proposal from the Commodity Futures Trading Commission (CFTC) to categorize them as gambling or gaming. I wish to highlight the potential ramifications and provide a different perspective, one that underscores the utility and necessity of election futures, while also addressing the concerns that have been raised.

    Election futures, at their core, bear a striking resemblance to the time-honored practice of commodities futures trading. In the global commodities markets, futures contracts are routinely used to manage the risk associated with volatile price movements of commodities like soybeans, oil, and gold. These contracts lock in prices today for future transactions, thus driving price stability and enabling users to hedge against possible future price changes. To illustrate, a farmer may use futures contracts to lock in a price for his crop weeks or months before harvest, protecting himself from a potential drop in prices.

    Similar to how futures trading harnesses the predictive power of the market to manage risk and uncertainty, election futures incorporate a greater breadth of information, knowledge, and collective wisdom to predict an electoral outcome. It is not, as has been proposed, anything like gambling. Instead, it is a rigorous analytical exercise that requires a deep understanding of political dynamics, public sentiment, demographic shifts, media influence, economic indicators, and historical voting patterns, among other factors. Election futures trading is not so much about luck as it is about knowledge, expertise, and the ability to make sense of a complex web of information.

    In addition, election futures have the capacity to provide a unique, market-driven evaluation of political sentiment that's more dynamic and potentially more accurate than traditional polling. This more fluid indicator could serve to enhance public understanding of the political landscape and contribute to deeper democratic engagement. This is in stark contrast to conventional polls, which are often plagued by bias, methodological flaws, and a failure to accurately capture the pulse of the population as a whole. As such, the idea of classifying election futures as gambling risks ignoring these nuanced benefits.

    Furthermore, it is important to consider how other nations engage with election futures. For instance, in the United Kingdom, political betting markets have long been a part of their democratic process. In fact, these markets have often been more accurate predictors of election outcomes than polls or pundits. It is not seen as gambling in a pejorative sense, but rather, as a sophisticated analysis of political dynamics. We have the opportunity to adopt a similar view here in the United States, bringing us in line with international norms, practices, and perceptions.

    I understand the CFTC's concerns regarding the potential influence of election futures on electoral integrity. The CFTC is concerned that large-scale trading on election outcomes might unduly influence the process itself. However, there are ways to mitigate the risks while preserving the utility of election futures. One potential solution could be imposing a cap on election futures contracts, similar to the campaign finance thresholds set by the Federal Election Commission. This approach could ensure that the market remains a tool for informed analysis, rather than a means of manipulation.

    By viewing election futures as a sophisticated extension of commodities trading, rather than a form of gambling, we can preserve their civic benefits and allow them to serve public interest. I implore the CFTC to reconsider their position and recognize the potential for election futures to contribute to a more informed and engaged electorate.

    I am happy to continue this dialogue and offer more insights on this critical issue at any time. I believe that our collective wisdom and deep understanding of both commodities trading and election futures can lead us to an equitable solution.

    Your time and attention to this matter are greatly appreciated.

    Yours sincerely,

    Michael Colopy]


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