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Comment for Proposed Rule 89 FR 48968

  • From: Ellis Moreno
    Organization(s):

    Comment No: 73969
    Date: 8/5/2024

    Comment Text:

    Dear CFTC,
    Drawing from my expertise in being a finance professor specializing in market behavior and predictive analytics, I have extensively studied the role of event contracts in enhancing market efficiency and transparency. My research has consistently demonstrated that these contracts provide significant value in terms of price discovery and risk management, particularly in the context of political events such as elections.
    Election contracts allow market participants to hedge against potential risks associated with political outcomes, which can have far-reaching economic consequences. These contracts are not merely speculative tools; they offer valuable insights into market expectations and can inform policy decisions, investment strategies, and economic forecasting. The data derived from these markets can also contribute to academic research, providing a rich source of information for analyzing market dynamics and investor behavior.
    The proposed restrictions on election contracts by the CFTC would undermine the progress made in this field and limit the availability of valuable data. These contracts are legal, regulated, and offer a structured environment for risk management. By restricting them, the CFTC risks driving this activity to less regulated and potentially more hazardous markets, which would reduce market transparency and increase systemic risk.
    Effective regulation should support innovation and market development while ensuring investor protection. I urge the CFTC to reconsider the proposed rules and engage with stakeholders, including academic researchers, to better understand the benefits of these contracts. Extending the comment period and holding a roundtable discussion would allow for a more informed and balanced regulatory approach.

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