DRAFT COMMENT LETTER
February __, 2025 Via email to: publicroundtables@CFTC.gov Caroline Pham, Acting Chairperson Commodity Futures Trading Commission
Three Lafayette Centre Washington, DC 20581 Re: Prediction Markets Roundtable: [Tribe/Tribal Organization] Comments Regarding Sports- Related Events Contracts Dear Chairperson Pham: The [Tribe/Tribal Organization] welcomes the opportunity to submit feedback and suggestions in advance of the Commodity Futures Trading Commission’s (“CFTC”) Prediction Markets Roundtable concerning sports-related event contracts (“Sports Contracts”). [Insert information about Tribe/Tribal Organization Here] . The [Tribe/Tribal Organization] strongly urges the CFTC to make it clear that Sports Contracts are prohibited from being listed or made available for clearing or trading. The listing and trading of Sports Contracts is directly contrary to the public interest for various reasons. Importantly, allowing Sports Contracts to be listed and traded would decimate the value of the bargained-for-exchange made between tribes and states in their gaming compacts, which generates vital revenue that supports both tribal and state governments and their citizens. Additionally, allowing Sports Contracts to be listed and traded would 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. Lastly, allowing Sports Contracts to be listed and traded would undermine the regulations and measures currently implemented by tribes and states to protect consumers and prevent criminal activity. To protect the public interest, therefore, it is crucial that the CFTC prohibit the listing and trading of Sports Contracts. I. Authorizing Sports Contracts Would Be Contrary to the Public Interest Allowing Sports Contracts to be listed or traded is not in the public interest and poses substantial policy concerns. First, allowing Sports Contracts to be listed and traded would depreciate the value of tribes’ bargained-for exclusivity to offer sports betting pursuant to compacts under the Indian Gaming Regulatory Act (“IGRA”), which in turn would threaten important government revenue that provides funding to both tribal and state governments. Second, allowing Sports Contracts to be listed and traded would interfere with and undermine tribal and state sovereignty. Third, unlike regulated sports betting conducted pursuant to tribal and state laws, Sports Contracts do not operate under robust regulations that address consumer protection and prevent criminal activity. As such, the CFTC should prohibit the listing and trading of Sports Contracts. A. Authorizing Sports Contracts Would Threaten Tribes’ Bargained-For Benefits and Vital Revenue from Gaming
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