DUE TOMORROW!  Model Comments – CFTC Advance Notice of Proposed Rulemaking Related to Prediction Markets

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April 29, 2026


 TO: Indian Gaming Association Member Tribes and Associate Members

FROM: David Z. Bean, Chairman
Jason Giles, Executive Director

RE: DUE TOMORROW!  Model Comments – CFTC Advance Notice of Proposed Rulemaking Related to Prediction Markets

Date:
April 29, 2026
On March 26, 2026, the Commodity Futures Trading Commission (“CFTC”) published an Advance Notice of Proposed Rulemaking (“ANPRM”) seeking public comment on matters affecting potential CFTC regulations that would apply to event contract derivatives traded on prediction markets. In the publication, the CFTC presents 40 questions for public input, falling into six related categories. 

The CFTC explains that this input will assist in formulating agency action on the matter of prediction markets and their potential to offer events contracts under the oversight of the CFTC. This ANPRM follows years of uncertainty due to the CFTC’s inaction on prediction markets offering sports-related events contracts or, as this concept is more informally known, unregulated sports betting. 

The Indian Gaming Association (“IGA”) is not convinced the CFTC is acting in the best of interests of Tribal nations or that any proposed regulation resulting from this Advanced Notice of Proposed Rulemaking will address the rapid expansion of unregulated sports betting and trampling of Tribal and State sovereignty. The Indian Gaming Association prepared the attached model comments for Tribes to use and modify as needed.

The deadline to provide written comments on this issue is April 30, 2026.  Comments may be submitted by mail to Christopher Kirkpatrick, Secretary of the Commission, Commodity Futures Trading Commission, Three Lafayette Centre, 1155 21st Street, NW, Washington, DC 20581 or by way of the CFTC comment portal, available at https://comments.cftc.gov. 

The advance notice of proposed rulemaking as it appears in the Federal Registermay be found here: https://www.govinfo.gov/content/pkg/FR-2026-03-16/pdf/2026-05105.pdf

Please contact Danielle Her Many Horses at dhermanyhorses@indiangaming.orgwith any questions or concerns with this alert.   
Download CFTC ANPRM Comment