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Comment for Industry Filing 22-002

  • From: Josh Fisher
    Organization(s):
    N/A

    Comment No: 69710
    Date: 9/18/2022

    Comment Text:

    These contracts should not be approved. CFTC has long held the consistent view that elections contracts are too tantamount to gambling, which is why it has consistently either prohibited them or restricted them only to academic nonprofits with heavy position limits. Indeed, elections contracts are a poor hedge to anything since a newly elected Congress isn't actually guaranteed to pass any particular legislation, or enact any particular policy that can ve hedged against. It's very hard to predict what Congress will do or when it will do anything. Since CFTC has long held the interpretation that elections contracts are too tantamount to gambling, could it and would it really suddenly change its interpretation now, especially without an appropriate act from Congress given that that the laws haven't been amended.

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