Caroline Pham, Acting Chairperson Commodity Futures Trading Commission Page 2 of 13
sufficiency through gaming and other forms of economic development. We are an educational, legislative, and public policy resource for tribal policy makers and the public on issues related to tribal community development and Indian gaming under the Indian Gaming Regulatory Act (“IGRA”). 25 U.S.C. § 2701 et seq. The IGA strongly urges the CFTC to make it clear that Sports Contracts are prohibited from being listed or made available for clearing or trading. Trading of Sports Contracts is gaming, violates state and federal law and is contrary to public policy for various reasons. Importantly, allowing Sports Contracts to be listed and traded will interfere with the sovereign right of tribes and states to exercise their police power to regulate gaming within their respective territories—a right long recognized by courts throughout the United States. Additionally, listing and trading Sports Contracts would decimate the value of the bargained-for-exchange made between tribes and states in their gaming compacts when tribes agree to share their gaming revenues – contributing billions Confederated Tribes of Siletz Indians; Confederated Tribes of the Colville Reservation; Confederated Tribes of the Umatilla Indian Reservation; Confederated Tribes of the Warm Springs; Coquille Indian Tribe; Cow Creek Band of Umpqua Tribe of Indians; Cowlitz Indian Tribe; Jamestown S’Klallam Tribe; Kalispel Tribe of Indians; Kootenai Tribe of Idaho; Muckleshoot Indian Tribe; Nez Perce Tribe; Port Gamble S’Klallam Tribe; Puyallup Tribe of the Puyallup Reservation; Shoshone-Bannock Tribes; Skokomish Indian Tribe; Snoqualmie Indian Tribe; Spokane Tribe of Indians; Suquamish Indian Tribe; Swinomish Indian Tribal Community; Tulalip Tribes; Agua Caliente Band of Cahuilla Indians; Berry Creek Rancheria of Maidu Indians; Big Sandy Rancheria of Western Mono Indians; Blue Lake Rancheria; Cahuilla Band of Mission Indians; Chicken Ranch Tribe of Me-Wuk Indians; Coyote Valley Band of Pomo Indians; Elk Valley Rancheria; Federated Indians of Graton Rancheria; Habematolel Pomo of Upper Lake; Mechoopda Indian Tribe of Chico Rancheria; Middletown Rancheria of Pomo Indians; Morongo Band of Mission Indians; Northfork Rancheria of Mono Indians; Pala Band of Mission Indians; Pechanga Band of Indians; Picayune Rancheria of Chukchansi Indians; Redding Rancheria, California; San Manuel Band of Mission Indians; Santa Rosa Rancheria Tachi Yokut Tribe; Scotts Valley Band of Pomo Indians; Sherwood Valley Band of Pomo Indians; Susanville Indian Rancheria, California; Sycuan Band of the Kumeyaay Nation; Table Mountain Rancheria of California; Tule River Indian Tribe; Tuolumne Band of Me-Wuk Indians; Twenty-Nine Palms Band of Mission Indians; Blackfeet Tribe; Confederated Salish & Kootenai Tribes of the Flathead Reservation; Northern Arapaho Tribe; Alabama-Coushatta Tribe; Iowa Tribe of Kansas & Nebraska; Kaw Nation; Kickapoo Tribe in Kansas; Sac and Fox Nation; Ohkay Owingeh Pueblo; Pueblo of Sandia; Pueblo of Santa Ana; Ak-Chin Indian Community; Fort McDowell Yavapai Nation; Gila River Indian Community; Pascua Yaqui Tribe; Salt River Pima- Maricopa Indian Community; San Carlos Apache Tribe; Tohono O’odham Nation of Arizona; and White Mountain Apache Tribe.
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