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Comment for Proposed Rule 89 FR 48968

  • From: Dan Ferraro
    Organization(s):

    Comment No: 73776
    Date: 6/14/2024

    Comment Text:

    Dear CFTC Recipient,

    I am writing to you as a market enthusiast and patriot who has faced professional repercussions for standing on my principles. My experiences have only deepened my appreciation for the integrity and transparency that regulated markets can offer.

    I am writing to express my views on the importance of election contracts, awards shows and contests, and sports contracts in the regulated marketplace.

    As someone who believes in the robustness of legal, regulated, and safe event contracts, I believe these contracts are essential because they provide a structured and secure platform for risk management and information dissemination. These contracts help market participants hedge against uncertainties and derive valuable insights from market trends and data.

    Furthermore, regulated activity in this space ensures that markets generate valuable information. This regulation not only secures the market but also allows for partnerships with reputable institutions, such as the recent collaboration between Kalshi and Susquehanna International Group, enhancing market liquidity and confidence.

    In light of the recent proposals by the CFTC, I would like to highlight that the election cop argument is not credible. The current interpretation undermines the potential benefits these contracts offer for risk management and market transparency. Additionally, the definition of gaming is wrong and overbroad, and the proposed regulations will drive activity offshore and ignore valuable data.

    I am concerned about the CFTC's approach. Effective regulation requires a collaborative approach, and I urge the CFTC to do the hard work to understand these markets. This means asking questions, considering comments, and engaging more actively with stakeholders to understand the practical implications of these regulations.

    Therefore, I respectfully request the Commission to extend the comment period, hold a roundtable discussion, and vote no on the proposed event contract rule. This will allow for more comprehensive feedback from the industry and ensure that all perspectives are adequately considered.

    In conclusion, election contracts, awards shows and contests, and sports contracts play a crucial role in the regulated marketplace. They offer legal, regulated, and safe avenues for market participants to hedge risks and gather valuable information. I appreciate your attention to this matter and look forward to a constructive dialogue on how best to regulate these essential contracts.

    Thank you for your consideration.

    Sincerely,

    Dan Ferraro"

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