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Comment for Proposed Rule 89 FR 48968

  • From: Mitchell Smith
    Organization(s):

    Comment No: 73835
    Date: 6/26/2024

    Comment Text:

    Dear CFTC Board,

    I am writing to you as a seasoned investor with over 25 years of experience to express my views on the importance of election contracts, awards shows and contests, and sports contracts in the regulated marketplace. Having diverse options available is crucial for making informed financial decisions. The proposed restrictions by the CFTC are not a regulation—they are a restriction that undermines the utility of these contracts.

    As someone who deeply understands the market, these contracts are not only legal, regulated, and safe, but they are essential because they provide market participants with valuable tools for hedging and price discovery, enhancing market liquidity and confidence.

    CFTC’s argument against election contracts is not credible. The current interpretation of 'gaming' is far too broad and incorrect, potentially driving market activity offshore and ignoring substantial data that supports the economic and hedging utility of these contracts. Effective regulation requires nuanced understanding and engagement with stakeholders, which seems lacking in the current approach. I respectfully urge the Commission to vote no on the proposed event contract rule and hold a roundtable discussion to allow for more comprehensive feedback from the industry. This will ensure that all perspectives are adequately considered, leading to more effective and informed regulatory decisions.

    These contracts are vital for risk management and market transparency. I appreciate your attention to this matter and look forward to a constructive dialogue on moving forward to regulate these essential contracts.

    Thank you for your time,
    Mitchell Smith

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