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Comment for Proposed Rule 89 FR 48968

  • From: Keith W Middlemark
    Organization(s):

    Comment No: 73790
    Date: 6/20/2024

    Comment Text:


    To the Commissioners of the Commodity Futures Trading Commission (CFTC),

    I am writing to express my profound concerns regarding the recent regulatory actions taken by the CFTC concerning event contracts. It is my firm belief that event contracts fall outside the appropriate scope of the CFTC's regulatory purview and that the Commission's recent steps to regulate these markets represent a significant overreach.

    Historically, the CFTC's mandate has been to oversee commodity futures and options markets, ensuring their integrity and stability. Event contracts, which often relate to political outcomes or other non-commodity-related events, do not fit neatly into the traditional categories of financial instruments that the CFTC is tasked with regulating. Their nature and purpose are fundamentally different from the commodities markets that the Commission was established to oversee.

    Moreover, this regulatory expansion appears to be politically motivated, coinciding suspiciously with the emergence of event market data that indicated favorable outcomes for former President Trump over President Biden. Such timing raises concerns about whether the regulatory action is being driven by political considerations rather than a genuine need to oversee these markets. If event markets are showing results that are politically unfavorable to the current administration, intervening to regulate them might be perceived as an attempt to suppress these signals, which undermines public trust in regulatory institutions.

    Event markets serve a valuable role in providing real-time insights into public sentiment and expectations, often reflecting the collective wisdom of a diverse group of participants. Traditional polling methods have long been criticized for their potential biases and inaccuracies. Event markets offer an alternative by aggregating the opinions and information of participants who have a financial stake in the outcomes. This can lead to a more accurate and nuanced understanding of public opinion and electoral probabilities. By moving to regulate these markets, the CFTC risks diminishing the quality and availability of this innovative source of information.

    In conclusion, I urge the CFTC to reconsider its stance on event contracts. The regulation of these markets does not align with the Commission's primary responsibilities and threatens to undermine an important tool for gauging public sentiment. The overreach into this domain not only deviates from the CFTC's core mission but also has the potential to erode trust in both the markets and the regulatory process itself.

    Thank you for considering my concerns. I hope the CFTC will take these points into account and refrain from further actions that could stifle the beneficial contributions of event markets.

    Sincerely,

    Keith Middlemark

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