March 10, 2026
Congressman Jeff Hurd House of Representatives 1641 Longworth House Office Building Washington, D.C. 20515 Re:
Commodities Futures Trading Commission And Prediction Markets
Dear Congressman Hurd: I want to follow-up on our introduction in February at the Capitol Hill Club and our discussion about so-called prediction markets and their intrusion on State and Tribal sovereignty, especially as it relates to sports betting and casino style gambling. As the new Chairman of the Indian Gaming Association (“IGA”), and its over 120 federally recognized Indian Tribes I want to personally provide you some background on the proliferation of illegal sports and events wagering across the Country in every jurisdiction including the 3 rd District of Colorado. In April 2025, with very little notice and in disregard of the Administrative Procedures Act (APA), an acting Commissioner at the Commodities Futures Trading Commission’s (CFTC) reversed the long-standing policy against gambling contracts. Since that announcement in April 2025, there has been a rapid expansion of online sports betting and what prediction market companies euphemistically refer to as “event contracts,” which in actuality is pure sports gambling and other nebulous bets on the weather, pop culture, and even elections. This rapid expansion of betting outside of State jurisdiction has prompted multiple schemes and attempted shortcuts to skirt federal, state and tribal laws. In response to this sudden proliferation of unregulated and unlawful sports betting, over twenty (20) states have issued cease and desist letters to KalshiEX, Crypto.com, Robinhood, Polymarket, among others. These State actions note that the market providers are in violation of state law and regulatory requirements for sports wagering and order the markets to immediately cease offering sports- related contracts. In response, prediction market companies have sued Nevada, New Jersey, Utah, Massachusetts, and Maryland, seeking preliminary injunctions preventing enforcement of state law. Fortunately, instead of relying on expensive and drawn-out litigation to enforce the Commodities Exchange Act, your colleagues Representative Moore (R-UT) and Carbajal (D-CA) have introduced a Bill to prohibit event contracts on sports betting, gaming, war, terrorism, elections, and other activities contrary to the public interest.
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